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V0868-26 ·21 April 2026 ·consulta-vinculante Medium impact
Tax

Separation of activities may qualify for fiscal neutrality if activity branch and participation criteria are met

A company wishes to segregate several of its activities into new entities to improve management and attract investors. The DGT states that for the fiscal neutrality regime to apply, the transferred elements must constitute an activity branch (an autonomous economic unit) and meet participation and residence requirements.

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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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