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V2157-21 ·29 July 2021 ·consulta-vinculante Medium impact
Tax

Total demergers ineligible for special Corporate Tax regime without establishment of a business line

An agricultural company intends to undergo a total demerger to divide its assets among three new companies, one for each family group. The Directorate General for Taxes (DGT) has ruled that the operation cannot benefit from the special Corporate Tax regime because the existence of autonomous business lines within the transferring company has not been proven.

In 6 key points

How it affects those involved

Companies planning demergers must ensure that the assets being transferred constitute distinct and autonomous business lines to qualify for tax relief under the special regime.

Lifecycle

2021-07-29PublishedPublished 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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