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V0931-21 ·15 April 2021 ·consulta-vinculante Medium impact
Tax

Partial spin-off does not qualify under special IS regime if segregated assets lack own materials and personnel

A company distributing spare parts and intending to start real estate promotion asks whether a partial or total spin-off can be carried out under the special IS regime. The DGT determines that a partial spin-off does not qualify if the new activity lacks its own material and human resources prior to the operation.

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2021-04-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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