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A frozen food trading company intends to carry out a partial spin-off to separate its real estate leasing activity into a new company. The DGT examines whether the real estate assets, including a mixed-use warehouse, constitute an autonomous line of business to qualify for the tax neutrality regime.
FIRST question raised. Whether the set of real estate assets intended for the real estate leasing activity, including the industrial warehouse partially used for the commercial activity carried out by the Company, may constitute an autonomous line of business for the purposes of the provisions of Article 76.4 of Law 27/2014, of November 27, on Corporate Income Tax.
Partial demerger may qualify for the tax neutrality regime if the segregated assets constitute a line of business (an autonomous economic unit capable of operating by its own means) and another line of business is maintained in the demerged entity. The existence of a mixed-use property does not prevent the demerger provided that the commercial activity can continue under analogous conditions, for example, through leasing. The application of this regime requires that the primary objective of the operation is not tax fraud or evasion.
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