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A company inquires whether the segregation of its industrial warehouses into a new company may qualify for the special partial spin-off regime. The DGT responds that, for this to occur, the segregated assets must constitute a line of business that is autonomous and distinct from the activity of the original company.
Question posed 1. Whether the described operation may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To benefit from the special partial spin-off regime, the segregated assets must constitute a line of business that is an economic unit capable of operating by its own means. This requires that the activity to be carried out by the transferee already exists within the transferor and possesses a distinct business organization. If the segregated assets are merely elements assigned to the main activity and not an autonomous undertaking, tax neutrality does not apply.
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