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V1897-25 ·14 October 2025 ·consulta-vinculante Low impact
Tax

Partial financial reverse spin-off may qualify for fiscal neutrality

A family company asks whether it can carry out a partial spin-off of its shares in a subsidiary to separate business activities and facilitate generational transition. The DGT responds that the operation may be covered under the special regime for mergers and spin-offs if it meets commercial requirements and does not have fraudulent purposes.

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2025-10-14PublishedPublished 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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