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V1958-25 ·16 October 2025 ·consulta-vinculante Low impact
Tax

Requirements for the application of the tax neutrality regime in total spin-off operations

The DGT states that if LIS requirements are met and the main objective is not tax fraud or evasion, the operation is fiscally neutral.

In 6 key points

How it affects those involved

Such a corporate split may qualify for fiscal neutrality under specific conditions, providing tax advantages without triggering liability.

Lifecycle

2025-10-16PublishedPublished 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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