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V2264-18 27 July 2018 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · escisión parcial

Special spin-off regime cannot be applied if segregated assets do not constitute a line of business

A company inquired whether the segregation of assets intended for stevedoring could qualify for the special partial spin-off regime. The DGT ruled that it cannot, as the transferred elements do not form an autonomous economic unit or a pre-existing line of business.

The question raised

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

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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