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A real estate development company has enquired whether the demerger of its agricultural activity can qualify for the special tax regime. The DGT indicates that it must comply with commercial regulations and that the transferred assets must constitute an autonomous business line with a distinct organisation.
Question posed: Whether the aforementioned operation may qualify for the special tax regime of Chapter VIII of 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 spin-off regime of the TRLIS, the operation must be carried out under the requirements of commercial regulations and the segregated assets must constitute an autonomous economic unit (branch of activity). This requires that the activity previously exists in the transferor and possesses a differentiated business organization. Furthermore, the operation must respond to valid economic motives, such as the restructuring or rationalization of activities, and must not have the primary purpose of tax fraud or evasion.
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