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A company inquires whether the spin-off of a leased property can qualify for the special Corporate Income Tax regime. The DGT responds that it cannot, as the property is an isolated asset and not a line of business with its own organization.
Question posed 1) Whether the described operation can 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 partial spin-off regime, the segregated assets must constitute a line of business, understood as an autonomous economic unit with differentiated material and human resources. In the case of real estate leasing, at least one employee with a full-time employment contract is required for an economic activity to exist. If the transferred element is an isolated asset without its own prior business organization, it does not meet the requirements of Article 76.4 of the LIS.
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