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V1520-25 ·21 August 2025 ·consulta-vinculante Low impact
Tax

Possibility of opting for the tax neutrality regime in mergers by absorption of wholly owned subsidiaries

A company holding 100% of another intends to carry out a merger by absorption to simplify its structure and facilitate generational succession. The DGT rules that, provided the transaction meets commercial requirements and is not intended for fraud, the special tax neutrality regime for Corporate Income Tax may apply.

In 6 key points

How it affects those involved

Companies undergoing corporate restructuring through mergers between parent and subsidiary can benefit from tax neutrality, provided the operation has a genuine commercial purpose.

Lifecycle

2025-08-21PublishedPublished 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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