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A real estate leasing company inquires whether its non-proportional total spin-off may qualify for the special regime of Corporate Income Tax. The DGT responds that, as it involves the transfer of isolated real estate assets without a differentiated business organization, the line of business requirement is not met.
Question posed: Whether the described operations could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
For a non-proportional total spin-off to benefit from the special regime, each of the segregated assets must constitute a line of business, understood as an autonomous economic unit capable of operating by its own means. This requires a differentiated business organization and a management model that corresponds to the nature of the operation. If the transaction only transfers a set of isolated elements, such as real estate, without meeting these requirements, the special regime is not applicable.
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