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V0708-25 ·15 April 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying fiscal neutrality regime to split transactions, asset contributions and total splits

A consultancy proposes a restructure involving total and financial splits, non-cash contributions of real estate and shares, and a final split to separate its industrial and real estate businesses. The inquiry asks whether these transactions may qualify for the special fiscal neutrality regime under Corporate Income Tax.

In 6 key points

How it affects those involved

The proposed transactions could qualify for fiscal neutrality, potentially avoiding tax liabilities on asset transfers and business separations, provided certain conditions are met.

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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