Skip to content
V2354-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

The merger of wholly owned subsidiaries may qualify for the tax neutrality regime under specific conditions

The DGT states that the merger may qualify for fiscal neutrality, but the split is only valid if the segregated assets constitute distinct activity branches.

In 6 key points

How it affects those involved

The fiscal neutrality of a merger followed by a total split depends on whether the segregated assets form distinct activity branches.

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