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V0229-24 ·29 February 2024 ·consulta-vinculante Medium impact
Tax

For a non-proportional total demerger to be tax-neutral, assets must constitute business lines

A company has requested a ruling on whether segregating its two activities (carpentry/locksmithing and flooring manufacturing) into two new entities constitutes a non-proportional total demerger under the tax neutrality regime. The DGT ruled that to apply this regime, the segregated assets must constitute business lines, meaning autonomous economic units capable of operating independently.

In 6 key points

How it affects those involved

Companies undergoing restructuring must ensure that segregated assets are structured as autonomous business lines to qualify for tax neutrality in non-proportional demergers.

Lifecycle

2024-02-29PublishedPublished 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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