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V2283-25 ·25 November 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying the tax neutrality regime in mergers by absorption of wholly owned companies

The DGT confirms that a merger by absorption between fully owned companies may qualify for the fiscal neutrality regime if conducted in accordance with commercial law and meets LIS requirements.

In 6 key points

How it affects those involved

Companies with full ownership of other entities may benefit from fiscal neutrality under specific merger conditions.

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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