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A real estate entity has enquired whether its restructuring plan, which includes a partial demerger of its land and development business, can benefit from the special regime for mergers and demergers. The DGT has ruled that this is possible provided the transaction meets the requirements of the Corporate Income Tax Act and is supported by valid economic reasons.
Question raised 1) Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of the Corporate Income Tax Law 27/2014, of November 27.
The operation may qualify for the special regime under Chapter VII of Title VII of the LIS if the segregation constitutes a line of business (autonomous economic unit) and the entity maintains another line of business. The economic reasons alleged for the restructuring are considered valid pursuant to Article 89.2 of the LIS. The beneficiary entity subrogates into the rights to offset negative tax bases of the transferred line of business, subject to the limitation of Article 84.2 of the LIS. Regarding the ITPAJD, the spin-off is considered a restructuring operation, therefore it is not subject to the corporate operations modality and is exempt from the other modalities.
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