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V2859-23 ·24 October 2023 ·consulta-vinculante Medium impact
Tax

Merger by absorption may qualify for the tax neutrality regime if legal requirements are met and valid economic reasons exist

A consulting company proposes a merger by absorption of three entities wholly owned by it. The DGT explains that the operation may apply the special tax neutrality regime if carried out for commercial purposes and meets the requirements of the Corporate Income Tax Act, provided that its primary objective is not tax fraud or tax advantage.

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2023-10-24PublishedPublished 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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