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The applicant inquired whether a demerger of real estate activity could qualify for the special regime for mergers and demergers under Corporate Income Tax. The DGT ruled that for this to apply, the segregated assets must constitute an autonomous line of business, with its own resources and a distinct organisation that already existed within the transferring entity.
Question posed: Whether the described operations can qualify for the tax regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax in the operations previously described, namely:
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