Skip to content
V2274-25 ·25 November 2025 ·consulta-vinculante Low impact
Tax

Absorption merger of wholly-owned companies may qualify for fiscal neutrality

A consulting company asks whether a merger by absorption of two entities (B and C), in which it holds 100% of the capital, can benefit from the fiscal neutrality regime. The DGT responds that if the operation complies with commercial law and Article 76.1(c) of the LIS, the fiscal neutrality regime may apply.

In 6 key points

Lifecycle

2025-11-25PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact