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V0610-26 ·17 March 2026 ·consulta-vinculante Medium impact
Tax

Non-cash contributions and spin-offs could qualify for fiscal neutrality if legal requirements are met

A company proposes a reorganisation through non-cash contributions and financial spin-offs to segment its logistics and real estate activities. The DGT states that these transactions may benefit from the fiscal neutrality regime provided the legal requirements are satisfied, such as a minimum 5% ownership stake in shareholders' equity.

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2026-03-17PublishedPublished 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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