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The query examines whether a partial demerger can qualify for the special regime under the Corporate Tax Act. The DGT rules that this is possible provided the segregated assets constitute a line of business with its own organisation and the transaction is supported by valid economic reasons.
Question posed: Whether the special regime for mergers, spin-offs, asset contributions, and exchange of securities provided for in Chapter VII of Law 27/2014 on Corporate Income Tax can be applied to a partial spin-off operation.
To apply the special regime, the spin-off must transfer a branch of activity that constitutes an autonomous economic unit capable of operating by its own means. This branch must be previously identified within the transferring entity and possess a distinct business organization. Furthermore, the primary objective of the operation must not be the attainment of a tax advantage, but rather valid economic motives such as the restructuring or rationalization of activities.
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