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V2403-25 ·10 December 2025 ·consulta-vinculante Low impact
Tax

Possibility of applying fiscal neutrality regime in absorption mergers if not for fraud

A company subject to common tax rules asks whether an absorption merger of a fully-owned subsidiary can benefit from the special fiscal neutrality regime. The DGT responds that such a regime applies if the transaction meets LIS requirements and does not primarily aim at fraud or tax evasion.

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2025-12-10PublishedPublished 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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