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V0123-26 27 January 2026 · SG de Impuestos sobre las Personas Jurídicas Analysis pending
IS · escisión parcial

Application of special split regime requires valid economic grounds

An energy company wishes to carry out a partial split to separate its conventional hydraulics division from its pumping division, enabling a new partner to join. The inquiry asks whether the special tax neutrality regime can be applied and whether it can retain in the split entity tax-deferred assets and negative taxable bases unrelated to the transferred business line.

Analysis pending. This ruling has been identified and indexed by the automatic ingestion system. BMC's team will complete the plain-language analysis within 24 hours. You may access the official source in the meantime.

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