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V2351-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

Total non-proportional spin-off requires segregated assets to constitute distinct business lines for fiscal neutrality

A consulting entity proposes an absorption merger followed by a total non-proportional spin-off into five new companies. The DGT states that for fiscal neutrality to apply, the segregated asset blocks must constitute distinct business lines.

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2025-12-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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