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V0035-26 9 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · neutralidad fiscal

Requirements for claiming fiscal neutrality in the contribution of a business activity branch

A taxpayer wishes to contribute their real estate leasing activity to a new company to facilitate generational transition and limit liability. The DGT examines whether the operation meets the conditions for qualifying under the fiscal neutrality regime of the Corporate Income Tax.

The question raised

Question raised 1.) Whether the described operations could qualify for the tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and whether valid economic reasons exist.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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