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V0654-15 ·23 February 2015 ·consulta-vinculante Medium impact
Tax

Partial spin-off cannot qualify for special regime if segregated assets do not constitute a separate activity branch

A real estate promotion company seeks to split its property rental activity by establishing a new entity. The DGT states that, as there was no prior autonomous organizational structure for rental activities, the requirement of a distinct activity branch is not met.

In 6 key points

How it affects those involved

Companies planning partial spin-offs must ensure that the segregated activity has a prior autonomous organizational structure to qualify for the special regime.

Lifecycle

2015-02-23PublishedPublished 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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