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V2437-22 ·25 November 2022 ·consulta-vinculante Medium impact
Tax

Absorption merger may qualify for tax neutrality if valid economic reasons exist

The DGT confirms that an absorption merger may apply for the special tax neutrality regime if it has valid economic grounds, not merely fiscal ones. The impact on negative taxable bases and inter-company loans is also addressed.

In 6 key points

How it affects those involved

The tax neutrality regime applies only if the merger has valid economic justification, not purely fiscal motives. Negative taxable bases and inter-company loans are affected accordingly.

Lifecycle

2022-11-25PublishedPublished 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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