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MEDIUM
FISCAL

Tax neutrality does not apply to partial demergers if the segregated assets do not constitute a line of business

V0183-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V0183-25
Published
14 Feb 2025

Summary

The taxpayer proposes a partial demerger to transfer real estate assets to a new company dedicated to leasing. The DGT responds that if the assets do not form an autonomous economic unit or a pre-existing line of business, the tax neutrality regime cannot be applied.

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