Skip to content
V5477-26 ·14 August 2026 ·consulta-vinculante Medium impact
Tax

Potential application of tax neutrality in mergers and subrogation into the tax consolidation regime

A holding company (A) intends to absorb another company (B), which is the dominant entity of a tax group. The inquiry examines whether the merger qualifies for tax neutrality, whether the economic reasons are valid, and how this affects tax consolidation.

In 6 key points

Lifecycle

2026-08-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact