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V2052-25 ·4 November 2025 ·consulta-vinculante Low impact
Tax

Total non-proportional spin-off requires segregated patrimonies to constitute activity branches for fiscal neutrality

A group of partners wishes to carry out a total non-proportional spin-off of three companies to establish three new entities (Newcos) to facilitate family succession. The DGT states that, as this is a non-proportional spin-off, the transferred patrimonies must constitute activity branches to apply the special regime.

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2025-11-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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