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MEDIUM
FISCAL

Requirements for the application of the tax neutrality regime in partial demergers

V0182-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V0182-25
Published
14 Feb 2025

Summary

A consulting company proposes a partial demerger of its assets (premises and housing) into a new company to carry out leasing activities. The DGT responds that, if the segregated assets do not constitute an autonomous and differentiated branch of activity within the transferring company, the operation does not qualify for the special tax neutrality regime.

In 6 key points

Lifecycle

2025-02-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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