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A company inquired whether the transfer of its real estate activity to another entity within the group could be considered a partial demerger. The DGT responds that it is possible if the transferred assets constitute an autonomous economic unit capable of operating by its own means.
Question posed: Whether the transfer of part of its assets, according to the described situation, can be considered a line of business for the purposes of partial demerger under the terms of Article 76.2.1.b) of Law 27/2014.
For a partial demerger to qualify for the special regime, the segregated assets must constitute a line of business, understood as a set of elements capable of operating by its own means. This tax concept does not necessarily require compliance with the economic activity requirements of Article 5 of the LIS, but rather requires a distinct business organization. The transaction must be carried out for valid economic reasons and not with the primary objective of obtaining a tax advantage.
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