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V0472-21 ·4 March 2021 ·consulta-vinculante Medium impact
Tax

Special spin-off regime cannot be applied if segregated assets do not constitute autonomous business lines

A query was raised regarding whether a partial spin-off of activities could qualify for the special regime under the Corporate Tax Act. The DGT ruled that, as a distinct and autonomous business organisation for each activity was not demonstrated, the transaction fails to meet the necessary tax requirements.

In 6 key points

How it affects those involved

Companies undertaking partial spin-offs must ensure that each segregated business line operates as a distinct and autonomous economic unit to benefit from the special tax regime.

Lifecycle

2021-03-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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