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V2352-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

Requirements for tax neutrality in merger and spin-off operations

DGT states that the merger may be neutral, but the split will only be neutral if the segregated assets constitute distinct activity branches.

In 6 key points

How it affects those involved

The tax neutrality of a total split depends on whether the segregated assets form distinct activity branches.

Lifecycle

2025-12-04PublishedPublished 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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