Skip to content
V2353-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

The merger of wholly owned subsidiaries may qualify for tax neutrality if it meets commercial and Corporate Income Tax Law requirements

The DGT states that the merger may qualify for fiscal neutrality, but the split is valid only if the separated blocks constitute autonomous activity branches.

In 6 key points

How it affects those involved

The validity of the split depends on the separated entities being independent activity branches, ensuring fiscal neutrality is maintained.

Lifecycle

2025-12-04PublishedPublished 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