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A company inquired whether the segregation of its real estate assets into a new company could qualify for the special regime for partial demergers. The DGT responds that to apply this regime, the segregated assets must constitute a line of business that operates by its own means and must have previously existed in the transferring company.
Question posed: Confirmation as to whether the described operation could apply the special regime for mergers, demergers, asset contributions, exchange of securities, and change of registered office of a European Company or a European Cooperative Society from one Member State to another of the European Union, as set forth in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and, if not, whether any other alternative may be available.
To benefit from the special regime for partial demergers, the segregated assets must constitute an autonomous economic unit (line of business) capable of operating by its own means. This requires that the economic activity of the transferee previously existed in the transferor and possesses a distinct business organization. If the segregated assets do not constitute a distinct line of business, the application of the tax neutrality regime shall not proceed.
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