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V0883-24 ·23 April 2024 ·consulta-vinculante Medium impact
Tax

The total spin-off of a company may qualify for the tax neutrality regime if it meets the requirements of the LIS

A family company managing rental properties proposes a total split to separate operations and facilitate succession. The DGT states that if the transaction meets commercial and proportionality requirements, it may apply the tax neutrality regime of the Corporate Income Tax.

In 6 key points

How it affects those involved

The proposed total split could allow the company to benefit from tax neutrality under the Corporate Income Tax, provided it meets commercial and proportionality criteria.

Lifecycle

2024-04-23PublishedPublished 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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