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MEDIUM
FISCAL

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

V2037-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2037-25
Published
29 Oct 2025

Summary

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.

In 6 key points

Lifecycle

2025-10-29PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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