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V5499-26 ·28 August 2026 ·consulta-vinculante Medium impact
Tax

Tax neutrality may apply to reverse mergers provided there is no intent to commit fraud

A consulting company has proposed a reverse merger in which the subsidiary absorbs the parent company to simplify the structure and improve governance. The Directorate General for Taxes (DGT) has ruled that the transaction may qualify for the special tax neutrality regime, provided it meets the requirements of the Corporate Income Tax Act and its primary objective is not tax fraud or evasion.

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2026-08-28PublishedPublished 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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