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V0897-18 ·9 April 2018 ·consulta-vinculante Medium impact
Tax

Total demergers may qualify for special Corporate Tax regime if proportional and based on valid economic grounds

A real estate rental company enquired whether a total demerger intended to resolve conflicts between divorced partners could qualify for the special Corporate Tax regime. The DGT indicates that this is possible provided the allocation of shares is proportional and the motives are economic, but not if the objective is to separate partners through capital reduction or if the demerger is not proportional.

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2018-04-09PublishedPublished 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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