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V0446-16 ·4 February 2016 ·consulta-vinculante Medium impact
FISCAL

Applicability of special regime for total spin-off under proportionality and valid economic grounds

The consultant asks whether their total spin-off may benefit from the special regime of Corporate Income Tax and whether the grounds are valid. The DGT responds that, as a proportional spin-off, it meets LIS requirements and that generational succession motives are considered valid economic grounds.

In 6 key points

How it affects those involved

Total spin-offs may qualify for the special regime if proportional and based on valid economic grounds such as generational succession.

Lifecycle

2016-02-04PublishedPublished 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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