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An agricultural company has enquired whether its total spin-off to create three new companies can qualify for the special Corporate Tax regime. The DGT has ruled that, as it is a non-proportional spin-off, it is an essential requirement that the spun-off assets constitute autonomous business lines, which cannot be inferred from the facts.
Cuestión planteada 1) Si la operación descrita puede acogerse al régimen fiscal especial del capítulo VIII, del título VII del Texto Refundido de la Ley del Impuesto sobre Sociedades aprobado por Real Decreto Legislativo 4/2004, de 5 de Marzo.
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