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A transport company inquired whether its partial spin-off could qualify for the special regime for mergers and spin-offs. The DGT ruled that this is not possible if the transferring company is left with only isolated elements that lack the capacity to carry out an autonomous economic activity.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the Recast Text of the Corporate Income Tax Law is appropriate for the proposed operation, and whether the alleged grounds are considered economically valid for these purposes.
To qualify for the special regime, the spin-off must transfer a line of business and the transferring company must maintain at least one other line of business. A line of business is understood as a set of assets capable of functioning by its own means as an autonomous economic unit. If the spun-off company is left only with isolated elements such as securities or bank accounts, it does not meet the requirements of Article 83.2 of the Recast Text of the Corporate Income Tax Law.
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