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A family real estate company seeks a total split to create three new entities and facilitate generational transition. The DGT determines the operation cannot apply the tax neutrality regime of the Corporate Income Tax as the transferred assets do not constitute pre-existing business lines.
Question raised 1. Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax, and whether the reasons indicated constitute valid economic reasons for the purposes of applying the aforementioned special regime.
For a non-proportional total spin-off to enjoy tax neutrality, the segregated assets must constitute business lines that operate by their own means. This requires the existence of a differentiated business organization and an autonomous economic exploitation previously identified within the transferring company. As these are isolated assets without a prior organizational structure, the operation does not meet the requirements of Article 76.4 of the LIS.
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