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An educational group requested a ruling on whether separating its teaching centres to create new companies constitutes a partial spin-off. The DGT ruled that, to qualify for the special tax regime, the transferred assets must constitute a line of business with its own organisation prior to the transaction.
Question posed: Whether the case presented would be treated as a spin-off or whether the decoupling of the teaching centers currently belonging to the company would not be so considered, as well as other issues related to the possible taxation of the centers following the projected operation.
To benefit from the special spin-off regime, the segregated assets must constitute an autonomous economic unit that allows for the development of an economic activity. This requires the existence of a differentiated organization of material and human resources for each activity within the demerged entity prior to the operation. In the case presented, it is not inferred that an educational center alone constitutes a branch of activity, nor that such prior organization exists.
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