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V1754-25 ·30 September 2025 ·consulta-vinculante Low impact
Tax

Requirements for eligibility for the tax neutrality regime in merger operations

A consulting company proposes a merger (absorption or reverse merger) to streamline its real estate activities. The DGT examines whether these transactions may qualify for fiscal neutrality and the offsetting of negative taxable bases.

In 6 key points

How it affects those involved

The analysis may affect the company's tax position by determining eligibility for fiscal neutrality and the offset of negative taxable bases.

Lifecycle

2025-09-30PublishedPublished 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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