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V5233-16 ·12 December 2016 ·consulta-vinculante Medium impact
Tax

Financial spin-offs under special regimes should not affect compliance with capitalisation reserve requirements

A query was raised regarding whether a financial spin-off that reduces equity would result in the loss of capitalisation reserve benefits. The DGT ruled that, where the special regime for spin-offs applies, compliance with the requirements is not affected.

In 6 key points

How it affects those involved

The ruling provides legal certainty for companies undergoing restructuring via financial spin-offs, ensuring that such operations do not disqualify them from tax benefits related to capitalisation reserves, provided they follow the special regime.

Lifecycle

2016-12-12PublishedPublished 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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