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MEDIUM
FISCAL

Absorption fusion of a fully owned company may qualify for fiscal neutrality

V1974-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1974-25
Published
20 Oct 2025

Summary

The DGT confirms that an absorption fusion of a fully owned company under Royal Decree-Law 5/2023 and meeting LIS requirements may apply the fiscal neutrality regime, provided it does not primarily aim at tax fraud or evasion.

In 6 key points

Lifecycle

2025-10-20PublishedPublished 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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