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V2350-25 ·3 December 2025 ·consulta-vinculante Low impact
Tax

Full non-proportional spin-off is tax-neutral only if segregated assets constitute distinct business units

The DGT states that a merger followed by a full non-proportional spin-off in five companies may be tax-neutral, but the spin-off will only be neutral if the segregated assets constitute distinct business units.

In 6 key points

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2025-12-03PublishedPublished 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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