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V1871-17 ·14 July 2017 ·consulta-vinculante Medium impact
Tax

Total demerger of a company may qualify for special Corporate Tax regime, exempting shareholders from Personal Income Tax

A consulting entity proposes a total demerger of its assets to transfer them to other companies. The DGT has ruled that the operation may qualify for the special Corporate Tax regime provided it meets commercial and economic requirements, and that individual shareholders will not be taxed on the demerger if this regime is applied.

In 6 key points

How it affects those involved

Companies undertaking total demergers can benefit from tax neutrality under the special Corporate Tax regime, provided they demonstrate valid economic reasons, thereby avoiding immediate tax liabilities for individual shareholders.

Lifecycle

2017-07-14PublishedPublished 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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