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V0186-25 ·14 February 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying the tax neutrality regime in merger by absorption operations

A consulting entity proposes an absorption merger to centralise management and reduce costs. The DGT determines that if the operation meets commercial and LIS requirements, the fiscal neutrality regime may apply.

In 6 key points

How it affects those involved

The merger may allow the entity to benefit from fiscal neutrality, provided it meets commercial and LIS requirements, potentially reducing tax liabilities and simplifying management through centralisation.

Lifecycle

2025-02-14PublishedPublished 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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