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The taxpayer asks whether the segregation of assets can qualify for the special partial spin-off regime. The DGT rules that, as there is no pre-existing separate organisation constituting a line of business, the transaction does not meet the requirements of Corporate Income Tax.
Question raised 1. Whether the proposed operation could qualify for the special tax regime regulated in Chapter VII of Title VII of the Corporate Income Tax Act. And whether the economic reasons presented can be considered valid for the purposes of applying the aforementioned special regime.
To benefit from the special regime for partial demergers, the segregated assets must constitute an autonomous economic unit capable of operating by its own means. This requires that the activity previously exists within the transferring entity with a distinct business organization. If the assets are isolated patrimonial elements without separate management, the special regime of the Corporate Income Tax Act cannot be applied.
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