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V0456-25 ·25 March 2025 ·consulta-vinculante Low impact
Tax

Requirements for a corporate merger to qualify for the tax neutrality regime

The DGT states that if the merger complies with commercial law and Article 76.1 of the LIS, it may benefit from fiscal neutrality, avoiding the consolidation of profits across companies and shareholders.

In 6 key points

How it affects those involved

The merger avoids tax consolidation, preserving the separate tax positions of the involved companies and shareholders.

Lifecycle

2025-03-25PublishedPublished 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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