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A company enquired whether the segregation of its real estate leasing activity could qualify for the special partial demerger regime under Corporate Income Tax. The DGT ruled that this is possible provided the transferred assets constitute an autonomous economic unit and other lines of business are maintained within the transferring company.
Question raised 1. 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 benefit from the special partial demerger regime, the segregated assets must constitute an economic unit capable of operating by its own means. Likewise, the activity must previously exist in the transferor and require a distinct business organization. The application of this regime is conditional upon the operation not having fraud or tax evasion as its primary objective, but rather valid economic reasons.
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