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V0007-25 ·2 January 2025 ·consulta-vinculante Low impact
Tax

The application of the limitation under Art. 84.2 LIS in mergers depends on the difference between the value of the contributions and their tax value

The DGT confirms that negative taxable bases are not reduced in a merger if losses are not offset between shareholders.

In 6 key points

How it affects those involved

Taxpayers in mergers can retain negative taxable bases if no double offset of losses occurs between shareholders.

Lifecycle

2025-01-02PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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