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V2374-25 ·9 December 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying the tax neutrality regime in a total spin-off under specific conditions

The DGT confirms that a total split, transferring property to an existing entity and the remainder to a new one, is tax-neutral if conducted under commercial and fiscal requirements.

In 6 key points

How it affects those involved

Such transactions are neutral for the company and its shareholders under the corporate tax regime.

Lifecycle

2025-12-09PublishedPublished 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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