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The applicant inquired whether the partial spin-off of land not related to their main activity allows for the application of the special Corporate Tax regime. The DGT ruled that, as these are isolated assets that do not form an autonomous economic unit, the legal requirements are not met.
Companies seeking to benefit from the special tax regime for spin-offs must ensure that the assets being separated constitute a distinct and autonomous line of business, rather than merely being isolated assets.
The tax team reviews your specific situation.
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