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V0416-26 ·26 February 2026 ·consulta-vinculante Medium impact
Tax

Partial spin-offs require distinct activity branches for tax neutrality

A company asked whether segregating part of its assets to create a new entity managing certain contracts would allow tax neutrality. The DGT replied that, due to the absence of independently organised and managed activity branches, the operation does not meet LIS requirements.

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2026-02-26PublishedPublished 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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