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The requesting entity asks whether the spin-off of properties intended for tourist accommodation can qualify for the special merger and spin-off regime. The DGT rules that this is not possible if the assets are isolated elements and do not form a business line with its own organisation.
Question posed: 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 valid economic reasons exist.
To apply the special regime, the segregated assets must constitute a line of business, understood as an autonomous economic unit with differentiated material and human resources. This autonomy must exist prior to the operation through a distinct business organization. If the spin-off only transfers isolated elements, such as specific real estate, without its own organization of resources, the requirements of the LIS are not met.
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