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The applicant asks whether a total spin-off and certain proposed partial spin-offs may qualify for the special regime under Corporate Income Tax. The DGT determines that a total spin-off may qualify provided legal requirements are met and there are valid economic reasons; however, the proposed partial spin-offs do not qualify because non-industrial assets do not constitute a business line.
Cuestión planteada Si a la operación de escisión total planteada le resultaría de aplicación el régimen especial regulado en el capítulo VII del título VII de la Ley 27/2014.
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