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V2344-23 ·28 August 2023 ·consulta-vinculante Medium impact
Tax

Partial demerger special regime requires the segregation of an autonomous line of business

A query was raised regarding whether the segregation of a real estate activity from a company that also provides clinical services can be considered a partial demerger under the special regime of Corporate Income Tax. The DGT indicates that for this to apply, the transferred assets must constitute a line of business capable of operating independently and must not have tax evasion as its primary objective.

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2023-08-28PublishedPublished 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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