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V2292-22 ·31 October 2022 ·consulta-vinculante Medium impact
Tax

To qualify for the special partial demerger regime, the segregated assets must constitute an autonomous line of business

The inquiry asks whether a partial demerger of an entity engaged in property leasing and agricultural activities can apply the special regime for Corporate Income Tax. The DGT rules that, for this to occur, the transferred assets must constitute a line of business with its own organisation and the transaction must be driven by valid economic reasons.

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2022-10-31PublishedPublished 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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