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V2355-25 ·4 December 2025 ·consulta-vinculante Low impact
Tax

Conditions for tax neutrality in merger and spin-off operations

The DGT states that the absorption merger may be tax-neutral, but the total non-proportional split will only be neutral if the separated blocks constitute autonomous activity branches.

In 6 key points

How it affects those involved

The tax neutrality of a merger followed by a total non-proportional split depends on whether the separated entities constitute autonomous activity branches.

Lifecycle

2025-12-04PublishedPublished 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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