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V2044-25 ·4 November 2025 ·consulta-vinculante Low impact
Tax

Fiscal neutrality in mergers depends on absence of fraud or tax evasion

A consulting company proposes an absorption merger with a company having negative taxable bases, citing economic reasons such as structural and management simplification. The DGT examines whether the transaction qualifies for the corporate tax neutrality regime.

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2025-11-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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