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V2311-25 ·27 November 2025 ·consulta-vinculante Low impact
Tax

Full spin-off may qualify for tax neutrality if LIS requirements are met

An agricultural exploitation company asks whether its plan to split into four entities can apply to the special regime for mergers and spin-offs. The DGT responds that tax neutrality is possible if the spin-off complies with commercial and LIS requirements.

In 6 key points

How it affects those involved

Companies considering full spin-offs may benefit from tax neutrality under specific conditions.

Lifecycle

2025-11-27PublishedPublished 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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