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A dental services company has enquired whether it can apply the special partial spin-off regime when segregating its rental properties. The DGT has ruled that this is not possible because the properties do not constitute an autonomous economic unit.
Question posed: Whether the described operation can qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.
To qualify for the special partial demerger regime, the segregated assets must constitute a line of business, understood as an economic unit capable of operating by its own means. In this case, the assets intended for leasing do not constitute a line of business as they are isolated elements without the material or human resources that allow for the development of an autonomous economic exploitation. Therefore, Article 76.4 of the LIS is not met.
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