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A company wishes to carry out a partial spin-off to separate its real estate from its IT networking activities in order to achieve fiscal neutrality. The DGT states that for this regime to apply, the segregated assets must constitute an autonomous business branch capable of operating independently, and such structure must already exist in the transferring company.
Whether the taxpayer may undertake a spin-off process of the business into companies A and B to transfer all real estate assets from company A to company B, which would manage their comprehensive operation, and to leave in company A the sole corporate purpose of network installation, requesting that this operation be tax-neutral and, therefore, exempt from taxation during the spin-off process
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