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V2672-22 ·29 December 2022 ·consulta-vinculante Medium impact
Tax

Partial spin-off of isolated assets does not qualify for special Corporate Tax regime

A hospitality company intends to carry out a partial spin-off to transfer its real estate assets to another company. The DGT ruled that, as the properties do not constitute a business line with a prior independent organisation, the transaction does not qualify as a tax-efficient spin-off.

In 6 key points

How it affects those involved

Companies cannot use spin-off tax benefits to transfer individual assets that do not function as an autonomous economic unit.

Lifecycle

2022-12-29PublishedPublished 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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