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V0399-25 20 March 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · escisión parcial

Requirements for fiscal neutrality in partial financial spin-offs

A company asks whether its partial financial spin-off operations may benefit from the special fiscal neutrality regime. The DGT responds that such operations may qualify for the regime if they are commercially classified as spin-offs and meet the LIS requirements.

The question raised

Question raised 1.- Confirmation that the projected demergers comply with all legally prescribed requirements to qualify for the special tax regime provided for in Chapter VII of Title VII of the LIS and, in particular, consideration of the alleged economic reasons as valid economic reasons for the purposes of allowing their inclusion in the special tax regime as provided for in Article 89.2 of the LIS.

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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