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V1912-25 ·15 October 2025 ·consulta-vinculante Low impact
Tax

Requirements for tax neutrality in partial demergers pursuant to the LIS and commercial regulations

The DGT states that if the properties do not constitute a separate activity branch with distinct organisation and management, the fiscal neutrality regime does not apply.

In 6 key points

How it affects those involved

The fiscal neutrality regime does not apply if the immovable assets do not form a distinct activity branch with independent organisation and management.

Lifecycle

2025-10-15PublishedPublished 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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