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V1944-15 19 June 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · escisión parcial

The special spin-off regime may be applied if a branch of activity with its own organization and valid economic reasons is segregated

The inquiry asks whether a partial spin-off of a company may qualify for the special regime of the Corporate Income Tax Act. The DGT responds that it is possible provided that the segregated assets constitute an autonomous economic unit and the operation is supported by valid economic reasons.

The question raised

Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.

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