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V1755-25 30 September 2025 · SG de Impuestos sobre las Personas Jurídicas Analysis pending
IS · escisión parcial

Requirements for the application of the tax neutrality regime in partial demerger operations

The DGT states that for tax neutrality, the transferred assets must form an autonomous activity branch with its own resources, which does not appear to be the case here.

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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