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V1907-25 ·15 October 2025 ·consulta-vinculante Low impact
Tax

Total non-proportional spin-off requires segregated assets to constitute distinct business activities for fiscal neutrality

A real estate leasing company asks whether its total non-proportional spin-off can benefit from fiscal neutrality. The DGT responds that, as no previously distinct business activities with independent structures existed in the transferring company, the transaction does not meet the requirements of the Corporate Income Tax.

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Lifecycle

2025-10-15PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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