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A transport company inquires whether the spin-off of two real estate properties into a new company may apply the special regime of the Corporate Income Tax Law. The DGT responds that, for this to occur, the segregated assets must constitute a line of business with its own organization.
Question posed: Whether the described operation may benefit from 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 distinct material and human resources. The transfer of isolated assets, such as real estate without a supporting business organization, does not meet this tax requirement. The autonomy of the line of business must exist within the demerged entity prior to the operation.
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