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A company involved in real estate development and property leasing has queried whether its partial demerger can qualify for the special Corporate Tax regime. The Directorate General of Taxes (DGT) has ruled that this is possible provided the transaction meets commercial requirements and the transferred assets constitute an autonomous line of business supported by valid economic reasons.
Question posed: Whether the described operation may benefit from the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To benefit from the special spin-off regime, the operation must comply with commercial regulations and the segregated assets must constitute a line of business, understood as a set of elements capable of functioning by its own means. The concept of a line of business does not require compliance with the economic activity requirements of the Personal Income Tax (IRPF) for the leasing of real estate. Furthermore, the operation must be carried out for valid economic reasons and must not have fraud or tax evasion as its primary objective.
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