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V1960-25 ·16 October 2025 ·consulta-vinculante Low impact
Tax

Fusion of a sole dependent entity extinguishes fiscal group, triggering proportional credit allocation and fiscal subrogation

The DGT clarifies that when an absorbing entity fuses with its only dependent entity, the dissolution of the fiscal group results in the proportional assignment of tax credits to the entities and the subrogation of the absorbing entity in the transmitting entity's tax bases.

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2025-10-16PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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