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V2054-25 ·4 November 2025 ·consulta-vinculante Medium impact
Tax

Partial spin-off requires segregated assets to form an autonomous business unit

The consultant proposes a partial spin-off of their assets (properties and a premises) to a new company for real estate activities. The DGT states that if the assets do not constitute an autonomous economic unit or a prior business activity in the transferring company, the operation does not qualify for fiscal neutrality.

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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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