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V0069-26 ·20 January 2026 ·consulta-vinculante Medium impact
Tax

Proportional total split of a company may qualify for fiscal neutrality

A family business asks whether a total split creating three new companies, maintaining proportional shareholder ownership, allows applying the fiscal neutrality regime. The DGT responds that if LIS requirements are met and the main objective is not fraud or tax evasion, the operation is neutral.

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2026-01-20PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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