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V2035-23 ·12 July 2023 ·consulta-vinculante Medium impact
Tax

Non-proportional total demerger requires the existence of business lines to qualify for the special Corporate Income Tax regime

A company inquires whether a non-proportional total demerger may apply the special regime for Corporate Income Tax (CIT), VAT, Personal Income Tax (PIT), Transfer Tax on Property Transfers and Legal Documents (ITPAJD), and Inheritance and Gift Tax (IIVTNU). The DGT determines that it does not meet the CIT requirements as it does not constitute business lines, although the operation is not subject to VAT.

Lifecycle

2023-07-12PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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