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V0554-26 ·10 March 2026 ·consulta-vinculante Medium impact
Tax

Fusion of a wholly owned subsidiary may qualify for tax neutrality under corporate tax

A consulting company proposes the absorption merger of a wholly-owned subsidiary. The DGT states that under the commercial framework of Royal Decree-Law 5/2023, the transaction may apply the corporate tax neutrality regime and be exempt from the ITPAJD.

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2026-03-10PublishedPublished 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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