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V0607-26 ·16 March 2026 ·consulta-vinculante Medium impact
Tax

Commercial centre contribution may qualify as activity branch contribution

A consultancy firm proposes to contribute its commercial centre management activity to a new company (Newco) to establish it as a SOCIMI. The DGT examines whether this transaction qualifies as a non-monetary activity branch contribution to apply the fiscal neutrality regime.

In 6 key points

How it affects those involved

The analysis determines whether the transfer of commercial centre management constitutes a non-monetary activity branch contribution, triggering the fiscal neutrality regime for the new SOCIMI entity.

Lifecycle

2026-03-16PublishedPublished 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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