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V0606-16 ·15 February 2016 ·consulta-vinculante Medium impact
Tax

Special spin-off regime applicable if LIS requirements are met and valid economic reasons exist

An entity has queried whether its spin-off operation can qualify for the special tax regime for corporate reorganisations. The DGT has ruled that this is possible provided the operation complies with commercial regulations and the requirements of the Corporate Income Tax Act (LIS), and as long as its primary purpose is not tax evasion or obtaining an undue tax advantage.

In 6 key points

How it affects those involved

This ruling provides legal certainty for companies seeking to restructure through spin-offs, confirming that tax neutrality can be achieved if the economic substance of the transaction is genuine and complies with statutory requirements.

Lifecycle

2016-02-15PublishedPublished 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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