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V1061-21 ·22 April 2021 ·consulta-vinculante Medium impact
Tax

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

The inquiry asks whether retail activity can be considered a line of business independent of wholesale activity. The DGT rules that, to apply the special spin-off regime, the assets must constitute autonomous economic units with distinct material and human resource organisations prior to the operation.

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2021-04-22PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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