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V0109-25 ·6 February 2025 ·consulta-vinculante Low impact
Tax

Possibility of opting for the tax neutrality regime in reverse mergers under specific conditions

A holding company (X) owning 100% of another (X1) proposes a reverse absorption merger to simplify its structure. The DGT seeks clarification on whether this transaction may qualify for the special tax neutrality regime and the scope of potential regularization.

In 6 key points

How it affects those involved

The proposed reverse merger may trigger tax neutrality considerations and could require regulatory alignment under specific conditions.

Lifecycle

2025-02-06PublishedPublished 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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