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V2277-25 ·25 November 2025 ·consulta-vinculante Low impact
Tax

The merger by absorption of a wholly owned subsidiary may qualify for the tax neutrality regime

A consulting company proposes the absorption merger of a subsidiary it wholly owns. The DGT states the transaction may qualify for fiscal neutrality if it meets LIS requirements and does not primarily aim at fraud.

In 6 key points

How it affects those involved

The transaction may benefit from fiscal neutrality under specific conditions, provided it complies with LIS criteria and lacks fraudulent intent.

Lifecycle

2025-11-25PublishedPublished 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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