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A company engaged in courier services, renovations, and leasing has queried whether its partial demerger, intended to separate its real estate activities, can qualify for the special Corporate Tax regime. The Directorate-General for Taxes (DGT) has ruled that, provided the requirements of an autonomous economic unit and valid economic reasons are met, the transaction is eligible for this regime and will not be subject to VAT, Stamp Duty (ITP/AJD), or Property Transfer Tax (IIVTNU).
This ruling provides legal certainty for companies undergoing restructuring, confirming that partial demergers can achieve tax neutrality if they meet specific structural and economic criteria.
The tax team reviews your specific situation.
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