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A query is made as to whether the transfer of three rural properties from an agricultural company can be considered a partial spin-off under the special regime of Corporate Income Tax. The DGT responds that, as there is no differentiated organization of material and human resources for those properties relative to the rest of the activity, the requirement of a branch of activity is not met.
Question posed
To qualify for the special partial spin-off regime, the segregated assets must constitute a branch of activity, understood as an autonomous economic unit with differentiated material and human resources. This requires the existence of a separate business organization for each asset group prior to the operation. If the segregation only transfers isolated assets without differentiated management, it is not considered a partial spin-off for tax purposes.
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