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The taxpayer proposes a partial demerger to transfer real estate assets to a new company dedicated to leasing. The DGT responds that if the assets do not form an autonomous economic unit or a pre-existing line of business, the tax neutrality regime cannot be applied.
Question raised
To benefit from tax neutrality in a partial demerger, the segregated assets must constitute a line of business, understood as a set of elements capable of functioning by their own means. This requires a distinct business organization and an autonomous economic exploitation that must exist previously in the transferring entity. If the segregation is limited to isolated assets, such as real estate, without a supporting organizational structure, the requirement of Article 76.2.1, letter b) of the LIS is not met.
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