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An entity involved in property rentals sought clarification on whether its various demerger options (total or partial, proportional or non-proportional) could benefit from the special Corporate Tax regime. The DGT ruled that only proportional total demergers meet the requirements, as the other options do not constitute distinct branches of activity.
Question raised 1) Whether the described operations could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
Proportional total demergers may qualify for the special regime under the Corporate Income Tax Act if the shareholders receive shares on a proportional basis. In contrast, non-proportional total demergers and partial demergers cannot benefit from the special regime because the mere separate management of real estate by different employees does not constitute a line of business or an autonomous economic unit. For partial demergers, it is required that the segregated assets constitute an economic unit capable of carrying out operations by its own means.
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