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V0549-25 ·28 March 2025 ·consulta-vinculante Low impact
Tax

Total severance not proportionate requires segregated assets to constitute activity branches

A hotel company wishes to carry out a total severance to divide its two hotels between two distinct family branches. The DGT examines whether this operation can be considered under the fiscal neutrality regime.

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2025-03-28PublishedPublished 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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