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A company wishes to carry out a total non-proportional spin-off to separate its property leasing and real estate promotion activities. The DGT states that the transaction cannot benefit from the special tax neutrality regime as the transferred elements do not constitute autonomous business activities.
Question raised 1) Whether the proposed non-proportional total spin-off operation is eligible for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law.
For a non-proportional total spin-off to qualify for the tax neutrality regime, the spun-off assets must constitute business lines that operate on their own merits. This requires a distinct business organization and an autonomous economic operation previously identifiable within the transferring company. In this case, the elements do not constitute business lines but are isolated assets; therefore, the special regime of the Corporate Income Tax Law does not apply.
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