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A company has requested clarification on whether a partial spin-off of a business line and a merger by absorption can qualify for the special Corporate Tax regime. The DGT has ruled that this is possible provided the segregated assets constitute an autonomous economic unit and the transaction is carried out for valid economic reasons rather than purely tax-driven purposes.
Cuestión planteada 1. Si los expuestos son motivos económicos válidos por los que la operación de escisión parcial de rama de actividad pueda acogerse al régimen especial del Capítulo VII del Título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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