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A company has enquired whether the spin-off of three industrial warehouses to its parent company may qualify for the special tax regime. The DGT has ruled that it does not, as the mere separation of real estate assets does not equate to the transfer of a line of business.
Question posed: Whether the described operation may qualify for the special tax regime under 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 qualify for the special spin-off regime, the segregated assets must constitute a line of business, understood as an economic unit capable of operating by its own means. The existence of a distinct business organization is necessary for the asset pool to be considered an autonomous economic exploitation. The mere separation of assets, such as industrial warehouses, without an organization that allows for their independent exploitation, does not fulfill this requirement.
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