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A company dedicated to real estate rental plans a total spin-off to divide into three new entities to facilitate generational succession. The DGT analyses the application of the special Corporate Tax regime, liability for Property Transfer Tax (IIVTNU), VAT, and Stamp Duty (ITP/AJD).
Question raised 1) Whether the described transaction may qualify for the special tax regime under 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.
The transaction may qualify for the special Corporate Income Tax regime if it is carried out within a commercial scope and for valid economic reasons, such as generational succession. In this case, the partners shall not include income from the attribution of values, and these shall be valued at their book value. The transfer of real estate shall be subject to VAT if it does not constitute an autonomous economic unit. Regarding Transfer Tax/Stamp Duty (ITP/AJD), the transaction shall not be taxed either because it is a non-taxable restructuring or because it is exempt. Finally, Article 108 of the LMV does not apply as it concerns a primary market transaction.
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