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V0342-25 ·19 March 2025 ·consulta-vinculante Medium impact
Tax

Non-proportional total split may qualify for fiscal neutrality if segregated assets constitute business units

A company with two activities (trade and leasing) asks whether a non-proportional total split can benefit from the special corporate tax regime. The DGT states that for this to apply, the transferred assets must constitute business units operating independently.

In 6 key points

How it affects those involved

Companies considering non-proportional splits should ensure that segregated assets form autonomous business units to qualify for fiscal neutrality.

Lifecycle

2025-03-19PublishedPublished 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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