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A company intends to carry out a partial demerger by transferring a set of loans to another entity within the group. The DGT responds that receivables do not constitute a line of business as they do not constitute an autonomous economic unit.
Question posed: Whether the reasons indicated are valid for applying the special regime established in Chapter VII of Title VII of Law 27/2014, on Corporate Income Tax, with effects on Corporate Income Tax, on Value Added Tax, on Transfer Tax and Stamp Duty, and on Personal Income Tax.
To benefit from the special demerger regime, the segregated assets must constitute a line of business, understood as an autonomous economic unit capable of operating by its own means. Elements comprised of several receivables against various debtors do not constitute a line of business. Therefore, the operation is not a partial demerger according to the LIS and cannot apply said special regime.
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