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A company involved in vehicle repair and car rental wishes to undergo a demerger to separate these two activities. The Directorate General for Taxes (DGT) rules that the operation may qualify for the special regime if the transferred assets constitute a business line and another is maintained within the original entity, provided that the motives are economic rather than purely tax-driven.
Cuestión planteada Si la operación descrita puede acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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