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V2037-25 ·29 October 2025 ·consulta-vinculante Medium impact
Tax

Partial spin-off of real estate activity requires establishment as an autonomous business branch for fiscal neutrality

A company wishes to carry out a partial spin-off to separate its real estate from its IT networking activities in order to achieve fiscal neutrality. The DGT states that for this regime to apply, the segregated assets must constitute an autonomous business branch capable of operating independently, and such structure must already exist in the transferring company.

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2025-10-29PublishedPublished 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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