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V0183-26 ·30 January 2026 ·consulta-vinculante Low impact
Tax

No rental income arises from the cancellation of participation in an absorption merger of a fully owned subsidiary

A parent company intends to absorb its wholly-owned subsidiary to rationalise its structure and reduce costs. The DGT seeks guidance on whether this improper merger can be treated under the fiscal neutrality regime.

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2026-01-30PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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