How the DGT's position has evolved
Current position
The transfer of a line of business to qualify for tax neutrality requires that the assets constitute an autonomous economic unit capable of operating by its own means. This requires a differentiated business organization that allows for the development of an autonomous economic exploitation in the acquiring entity. Furthermore, the activity must have previously existed in the transferor and the operation must respond to valid economic reasons.
The DGT's position has remained constant over time, defining a line of business as an autonomous economic unit with its own operating capacity. Throughout the rulings, the need for a differentiated business organization and an autonomous economic exploitation has been reinforced to avoid the mere segregation of isolated assets.
Analysis based on 64 of 72 rulings with a stated position. Updated 15 September 2026.