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V2294-22 ·31 October 2022 ·consulta-vinculante Medium impact
Tax

Special spin-off regime cannot be applied if segregated assets do not constitute a business line

A company inquired whether the partial spin-off of two properties into a new company could qualify for the special Corporate Tax regime. The DGT ruled that, as these are isolated assets without a distinct business organisation, they do not meet the requirement of being a business line.

In 6 key points

How it affects those involved

Companies attempting to spin off individual assets without an integrated business structure will be denied the tax benefits of the special spin-off regime.

Lifecycle

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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