Requirements for partial spin-off regime: need for an activity branch
Technical details
Summary
A company asks whether spinning off its property leasing activity to a new entity can qualify for fiscal neutrality. The DGT replies that the segregated assets must constitute an activity branch with economic autonomy, not just isolated assets.
In 6 key points
How it affects those involved
Companies considering partial spin-offs must ensure the segregated activity has economic independence to qualify for fiscal neutrality.