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A Spanish company proposes contributing its personal hygiene products division to a newly established company, retaining its cleaning and disinfection activities. The DGT concludes that if it can be proven that this activity has an independent corporate structure with distinct material and human resources, the definition of a business segment under Article 76.4 LIS is met, allowing the transaction to qualify for the fiscal neutrality regime.
Question raised 1.- Whether the contributed activity can be considered a branch of activity for the purposes of the provisions of Article 76 of the Corporate Income Tax Law (LIS).
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