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V1201-14 ·29 April 2014 ·consulta-vinculante Medium impact
Tax

Activity branch requirement for the special regime for non-proportional total demergers

A company operating two activities (property leasing and real estate development) has enquired whether its non-proportional total demerger can qualify for the special tax regime. The DGT indicates that the demerged assets must constitute distinct branches of activity within the originating entity, which requires a separate organisation of material and human resources.

In 6 key points

How it affects those involved

Companies planning non-proportional total demergers must ensure that the assets being split are structured as autonomous branches of activity with their own resources to qualify for the special tax regime.

Lifecycle

2014-04-29PublishedPublished 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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