Skip to content
V1695-25 ·18 September 2025 ·consulta-vinculante Medium impact
Tax

Possibility of applying fiscal neutrality regime in absorption mergers under legal and commercial requirements

The consultant asks whether a 100% subsidiary absorption merger can benefit from the special fiscal neutrality regime. The DGT responds that such a regime applies if the transaction meets commercial and Income Tax requirements, provided its main objective is not tax fraud or evasion.

In 6 key points

Lifecycle

2025-09-18PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact