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A real estate leasing and development company inquired whether its total demerger into three new companies could qualify for the special Corporate Income Tax regime. The DGT ruled that, as it is a non-proportional demerger, the transferred assets must constitute autonomous business lines, a requirement that was not met in this case.
Cuestión planteada 1º) Si la operación descrita puede acogerse al régimen fiscal especial del capítulo VII del Título VII de la Ley del Impuesto sobre Sociedades 27/2014, de 27 de noviembre.
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