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V1625-25 ·15 September 2025 ·consulta-vinculante Low impact
Tax

Mergers between companies held by the same shareholder may qualify for tax neutrality

An entity proposes to absorb another owned by the same sole shareholder to simplify management and optimise resources. The DGT rules that the transaction may apply the special tax neutrality regime, provided it meets commercial requirements and those set out in the Corporate Income Tax Act.

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2025-09-15PublishedPublished 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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