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The taxpayer proposes a non-proportional total spin-off of land for future real estate and hotel projects. The DGT rules that neither the special Corporate Tax regime nor the VAT exemption can be applied, as the assets do not constitute an autonomous line of activity within the transferring company.
Companies attempting to spin off assets for future business activities without an established, autonomous economic unit will not benefit from tax neutrality or VAT exemptions.
The tax team reviews your specific situation.
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