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V0018-25 ·9 January 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying the tax neutrality regime in mergers of companies wholly owned by the same shareholder

The DGT confirms that a merger may qualify for fiscal neutrality if it meets commercial requirements and is not aimed at fraud, even without share attribution or capital increase.

In 6 key points

How it affects those involved

Entities fully owned by a parent company may benefit from fiscal neutrality in mergers under specific conditions.

Lifecycle

2025-01-09PublishedPublished 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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