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A consulting company proposes a partial demerger of its assets (premises and housing) into a new company to carry out leasing activities. The DGT responds that, if the segregated assets do not constitute an autonomous and differentiated branch of activity within the transferring company, the operation does not qualify for the special tax neutrality regime.
Question posed: Whether the partial demerger described may qualify for the special regime under Chapter VII of Title VII of Law 27/2014 on Corporate Income Tax.
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