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V0655-25 ·10 April 2025 ·consulta-vinculante Low impact
Tax

Fusion could qualify for tax neutrality if LIS conditions met

A consultant asks whether the merger of two companies controlled by the same individual may qualify for tax neutrality and whether valid economic reasons exist. The DGT states that if the operation meets the conditions of Article 76.1 of the LIS, the tax neutrality regime may apply, allowing the substitution of negative taxable bases.

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2025-04-10PublishedPublished 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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