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V0862-26 ·21 April 2026 ·consulta-vinculante Medium impact
Tax

Non-proportional total split not covered by tax neutrality if assets do not constitute existing business lines

A family real estate company seeks a total split to create three new entities and facilitate generational transition. The DGT determines the operation cannot apply the tax neutrality regime of the Corporate Income Tax as the transferred assets do not constitute pre-existing business lines.

In 6 key points

How it affects those involved

Companies planning non-proportional splits must ensure transferred assets form existing business lines to qualify for tax neutrality under corporate tax rules.

Lifecycle

2026-04-21PublishedPublished 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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