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An entity inquired whether its partial demerger operation of the real estate leasing activity could qualify for the special regime of the TRLIS. The DGT responds that it is possible if the segregated assets constitute a business line with its own organization and valid economic reasons.
Question posed: Whether the aforementioned operation can 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 qualify for the special regime, the demerger must comply with commercial requirements and the segregated business line must be an economic unit capable of functioning by its own means. The concept of a business line does not require strict compliance with the economic activity requirements of the IRPF for real estate leasing. Furthermore, the operation must be carried out for valid economic reasons, such as the rationalization of activities, and not for the purpose of obtaining a tax advantage.
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