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V0521-18 ·23 February 2018 ·consulta-vinculante Medium impact
Tax

Total demergers may qualify for special tax regime if carried out for valid economic reasons

A company has requested a ruling on whether its demerger operation meets the requirements for the special demerger tax regime. The DGT indicates that if the operation is a commercial total demerger and is conducted for economic reasons rather than solely to obtain a tax advantage, the special regime may apply.

In 5 key points

How it affects those involved

Companies undergoing restructuring can benefit from tax neutrality if they can demonstrate that the demerger is driven by genuine economic purposes.

Lifecycle

2018-02-23PublishedPublished 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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