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V3238-21 ·29 December 2021 ·consulta-vinculante Medium impact
Tax

Partial demergers may qualify for special tax regime if segregated assets constitute business lines

A company engaged in wholesale trade and property leasing has requested a ruling on whether its partial demerger can qualify for the special Corporate Tax regime. The Directorate-General for Taxes (DGT) indicates that it must be proven that both the transferred and the retained assets constitute autonomous business lines and that valid economic reasons exist.

In 6 key points

How it affects those involved

Companies undergoing restructuring must ensure that demerged assets form independent business units and are supported by genuine economic justifications to benefit from tax neutrality.

Lifecycle

2021-12-29PublishedPublished 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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