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A company inquired whether the spin-off of a completed and unused real estate complex could qualify for the special partial spin-off regime. The DGT responds that it cannot, as the transferred assets do not constitute an autonomous line of business in the transferring company.
Question posed: Whether the described operation can qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
To apply the special regime, the spin-off must comply with the requirements of the TRLIS, which requires the segregated assets to be a line of business (an autonomous economic unit). The concept of a line of business does not require meeting the economic activity requirements of the IRPF, but it does require a distinct business organization. In this case, as the properties are unused, no prior economic exploitation is identified that would allow the assets to be considered a line of business.
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