Skip to content
V2359-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

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

A family entity asks whether a merger by absorption followed by a full non-proportional spin-off into five new companies can qualify for tax neutrality. The DGT states that the merger may be neutral, but the spin-off will only be neutral if the segregated blocks constitute distinct business units.

In 6 key points

Lifecycle

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

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact