Skip to content
V0209-26 ·4 February 2026 ·consulta-vinculante Medium impact
Tax

Splitting isolated immovable assets does not constitute a business activity for fiscal neutrality

A real estate leasing company intends to carry out a partial split to transfer blocks of assets to companies owned by its shareholders. The DGT states that if the immovable assets do not constitute a distinct business activity with independent organisation in the original company, the regime of fiscal neutrality will not apply.

In 6 key points

Lifecycle

2026-02-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact