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V0562-26 ·10 March 2026 ·consulta-vinculante Medium impact
Tax

Total non-proportional spin-off may qualify for fiscal neutrality if segregated assets constitute autonomous business lines

A company with two distinct activities seeks a total non-proportional spin-off so that each group of shareholders owns a new entity. The DGT states that for fiscal neutrality to apply, the segregated assets must constitute autonomous business lines.

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2026-03-10PublishedPublished 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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