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V0710-25 ·15 April 2025 ·consulta-vinculante Medium impact
Tax

Requirements for partial spin-off regime: need for an activity branch

A company asks whether spinning off its property leasing activity to a new entity can qualify for fiscal neutrality. The DGT replies that the segregated assets must constitute an activity branch with economic autonomy, not just isolated assets.

In 6 key points

How it affects those involved

Companies considering partial spin-offs must ensure the segregated activity has economic independence to qualify for fiscal neutrality.

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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