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A jewellery company that also owns rental properties has enquired whether it can carry out a partial demerger of said properties under the special Corporate Tax regime. The Directorate-General for Taxes (DGT) ruled that, as there was no prior separate organisation and management for these properties, they do not constitute a line of business and therefore do not qualify for the special regime.
Cuestión planteada Si las operaciones descritas pueden acogerse al régimen fiscal previsto en el Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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