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MEDIUM
FISCAL

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

V1695-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1695-25
Published
18 Sept 2025

Summary

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.

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