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V1094-21 ·27 April 2021 ·consulta-vinculante Medium impact
Tax

Special spin-off regime cannot be applied if beneficiary entities do not receive majority stakes

A real estate company inquired whether a partial financial spin-off of its holdings in other entities could qualify for the special tax regime. The Directorate General for Taxes (DGT) ruled that it cannot, as the receiving companies would only receive 33.33% of the shares, failing to meet the majority requirement.

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2021-04-27PublishedPublished 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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