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V2505-24 ·10 December 2024 ·consulta-vinculante Medium impact
Tax

Merger by absorption may qualify for tax neutrality if not intended for fraud

A company has requested a ruling on whether a merger by absorption of two subsidiaries can benefit from the tax neutrality regime and if it meets valid economic purposes. The DGT has determined that, provided the operation meets commercial requirements and the provisions of Article 76.1 of the LIS, such a regime may apply as long as the primary objective is not tax fraud or evasion.

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2024-12-10PublishedPublished 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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