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MEDIUM
FISCAL

Succession of business by subrogation does not imply multiple payers for IRPF

V2187-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2187-25
Published
17 Nov 2025

Summary

The DGT responds that, in the case of a business succession by subrogation, the new company retains the status of the same payer.

In 6 key points

How it affects those involved

The succession of a business by subrogation within the same group does not create multiple payers for IRPF.

Lifecycle

2025-11-17PublishedPublished 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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