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V2227-19 ·20 August 2019 ·consulta-vinculante Medium impact
Tax

Special spin-off regime cannot be applied if the operation is preparatory to a subsequent donation

A real estate management company has enquired whether its total spin-off can qualify for the special tax regime. The DGT indicates that although a proportional spin-off meets the requirements, if it is carried out to facilitate a subsequent donation of shares to minority shareholders, the operation is considered preparatory and does not qualify for the special regime.

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2019-08-20PublishedPublished 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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