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A real estate promotion company asks whether transferring isolated assets to a new entity can qualify for the special division regime. The DGT responds that it is not possible because the assets do not form an autonomous economic unit or a business branch.
Question posed: Whether the described operation may qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax
To apply the special regime for partial demergers, the segregated assets must constitute a line of business, understood as a set of elements capable of functioning by their own means. This requires the existence of a differentiated organization of material and human resources for each activity within the demerged entity prior to the operation. The transfer of isolated assets without a differentiated business organization does not meet this requirement.
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