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V1096-21 ·27 April 2021 ·consulta-vinculante Medium impact
Tax

Partial spin-offs do not qualify for special Corporate Tax regime if segregated assets do not constitute a line of business

A company has requested a ruling regarding a partial spin-off involving real estate services, solar panels, and hospitality. The DGT has determined that the operation does not meet the requirements for the special Corporate Tax regime as the assets do not constitute distinct lines of business, although the transaction remains outside the scope of VAT and is exempt from ITPAJD.

In 6 key points

How it affects those involved

Companies undertaking partial spin-offs must ensure that the assets being segregated constitute autonomous economic units or distinct lines of business to benefit from the special Corporate Tax regime.

Lifecycle

2021-04-27PublishedPublished 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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