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The taxpayer asks whether real estate activity can be considered an independent line of business to qualify for the special spin-off regime. The DGT responds that, based on the facts, these are isolated elements that do not form an autonomous economic unit.
Question posed: Whether the real estate business activity referred to in the consultation request can be considered an independent line of business and, therefore, whether the proposed partial spin-off operation can qualify for the special tax regime under Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special partial spin-off regime, the segregated assets must constitute a line of business, understood as a set of elements capable of operating by its own means. This requires a differentiated business organization and an autonomous economic operation within the transferring entity. In this case, as these are isolated elements without their own material and human resources, the requirement of Article 76.4 of the LIS is not met.
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