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V0926-24 ·25 April 2024 ·consulta-vinculante Medium impact
Tax

The total spin-off of a single-member company may qualify for the tax neutrality regime if legal requirements are met

The DGT states that if the split meets commercial and proportionality requirements, the regime may apply, provided the main objective is not fiscal advantage.

In 6 key points

How it affects those involved

A single-member company may benefit from a special tax neutrality regime upon total split, subject to commercial and proportionality conditions and absence of primary fiscal gain.

Lifecycle

2024-04-25PublishedPublished 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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