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A company enquired whether the partial demerger of its real estate business into a new company could qualify for the special Corporate Tax regime. The DGT ruled that this is possible provided the segregated assets constitute autonomous business branches and the transaction is driven by valid economic reasons rather than solely for tax advantages.
Question posed: Whether the described operation could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime for partial demergers, the operation must comply with the commercial and tax requirements of the Corporate Income Tax Act. It is necessary that the segregated assets constitute a line of business, understood as an economic unit capable of operating on its own with differentiated material and human resources. Furthermore, the operation must not have the primary objective of tax fraud or evasion, and must be based on valid economic motives such as the restructuring or rationalization of activities.
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