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A company engaged in rental and debt collection activities has enquired whether it can perform a partial spin-off of its real estate division into another company by applying the special Corporate Tax regime. The Directorate General for Taxes (DGT) responds that this is possible provided the segregated assets constitute an autonomous economic unit and the transaction is supported by valid economic reasons.
Cuestión planteada 1) Si la operación descrita puede acogerse al régimen fiscal especial del capítulo VIII, del título VII del Texto Refundido de la Ley del Impuesto sobre Sociedades aprobado por Real Decreto Legislativo 4/2004, de 5 de Marzo.
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