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V0184-25 ·14 February 2025 ·consulta-vinculante Low impact
Tax

The application of the tax neutrality regime in partial demergers requires that the segregated assets constitute a line of business

The DGT states that a partial spin-off of isolated assets, not a business unit with independent structure, cannot benefit from the special fusion and spin-off regime.

In 6 key points

How it affects those involved

Companies seeking to transfer isolated assets through a partial spin-off must operate under standard tax rules, not the special regime.

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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