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A real estate development and commercial rental company has requested clarification on whether spinning off its leasing business line into another company meets the requirements for the special tax regime. The Directorate General of Taxes (DGT) indicates that if the transaction is conducted on commercial terms and the segregated assets constitute an autonomous economic unit, the special regime may apply.
Question posed: Whether the special tax regime of Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax is applicable to the proposed operation. And whether the line of business of premises rental and the stated motive comply with the necessary requirements for the application of said regime.
To apply the special regime, the spin-off must be carried out within the commercial sphere and the segregated assets must constitute a line of business, understood as an economic unit capable of functioning by its own means. In the case of real estate leasing, it is not necessary to apply the economic activity criteria of Article 5 of the LIS, but rather to analyze whether an autonomous operation with a differentiated organization exists. The operation must not have fraud or tax evasion as its primary objective, but rather valid economic motives.
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