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V2329-23 ·10 August 2023 ·consulta-vinculante Medium impact
Tax

Special regime for partial demergers may apply if an autonomous line of business is transferred

The query examines whether a partial demerger can qualify for the special regime under the Corporate Tax Act. The DGT rules that this is possible provided the segregated assets constitute a line of business with its own organisation and the transaction is supported by valid economic reasons.

In 6 key points

How it affects those involved

Companies undertaking partial demergers must ensure the transferred assets form a distinct, organised line of business and demonstrate genuine economic substance to benefit from the special tax regime.

Lifecycle

2023-08-10PublishedPublished 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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