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V0706-25 ·15 April 2025 ·consulta-vinculante Medium impact
Tax

Fiscal neutrality not applicable in partial split if segregated assets do not form a distinct business activity

A real estate leasing company asks whether a partial split to divide its assets between two children can benefit from the fiscal neutrality regime. The DGT responds that, based on the information provided, the segregated assets do not appear to constitute a previously distinct and separate business activity, and thus the regime does not apply.

In 6 key points

How it affects those involved

Fiscal neutrality in partial splits is not available if the segregated assets do not constitute a distinct business activity.

Lifecycle

2025-04-15PublishedPublished 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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