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V0874-21 ·13 April 2021 ·consulta-vinculante Medium impact
Tax

Full spin-off may qualify under special regime if proportional or if entities constitute activity branches

A car dealership company asks whether its plan to split into three separate companies can use the special tax regime for IS. The DGT examines two scenarios: one with non-proportional distribution and one with proportional distribution.

In 6 key points

Lifecycle

2021-04-13PublishedPublished 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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