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A company operating two dental clinics intends to carry out a non-proportional total demerger to create two new entities, with each partner owning 100% of one clinic. The DGT ruled that the transaction cannot benefit from the special tax neutrality regime because the existence of two autonomous lines of business has not been proven.
Question posed: Whether the projected operation could benefit from the special tax regime regulated in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax (hereinafter, LIS).
For a non-proportional total demerger to benefit from the special regime, the segregated assets must constitute lines of business, understood as sets of elements capable of functioning by their own means. This requires a differentiated business organization for each asset set, motivated by the nature of the elements or the need for a separate management model. The fact of operating two centers of the same activity does not automatically imply the existence of two differentiated lines of business if there is no autonomous organization and management for each.
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