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V0189-25 ·14 February 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying the tax neutrality regime in mergers if the requirements of the CIT are met

The DGT confirms that a reverse merger driven by administrative simplification and cost reduction may qualify for fiscal neutrality, provided it meets commercial requirements and does not primarily aim at tax fraud or evasion.

In 6 key points

How it affects those involved

Such mergers can benefit from fiscal neutrality if they are legitimate business restructurings without fraudulent intent.

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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