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V5469-26 ·12 August 2026 ·consulta-vinculante Medium impact
Tax

Tax neutrality may apply to mergers between companies wholly owned by the same shareholder

A company inquired whether a merger by absorption involving three companies owned by the same sole shareholder could qualify for the special merger regime. The DGT ruled that tax neutrality can be applied even in the absence of capital increases or the allocation of securities, provided that commercial requirements are met and the transaction is not carried out for fraudulent purposes.

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2026-08-12PublishedPublished 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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