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V5012-26 5 June 2026 · SG de Impuestos sobre las Personas Jurídicas Analysis pending
IS · escisión parcial

Requirements for the application of the tax neutrality regime in partial demergers

A construction company inquired whether its partial demerger to create two new companies (one for leasing and another for development) could benefit from the special tax neutrality regime. The DGT ruled that, based on the facts, the segregated assets appear to be isolated elements rather than autonomous business units, meaning the regime would not apply.

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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