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MEDIUM
FISCAL

Partial spin-offs must constitute a business activity branch

V2443-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2443-25
Published
11 Dec 2025

Summary

The consultant asks whether a partial spin-off of commercial premises to a new company can benefit from the special regime for mergers and spin-offs. The DGT responds that to apply this regime, the segregated assets must form a business activity with economic autonomy, not just isolated financial elements.

In 6 key points

Lifecycle

2025-12-11PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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