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The DGT confirms that an absorption merger may benefit from fiscal neutrality if it meets legal requirements and is not intended for fraud. However, the extinguishment by confusion of a loan could generate taxable income in the absorbing company.
Question posed - Whether the absorbed company, Sociedad B, must be considered a patrimonial entity, given that it is part of a business group.
Si la fusión cumple los requisitos mercantiles y el artículo 76.1 a) de la LIS, puede aplicar el régimen de neutralidad fiscal. Bajo este régimen, no se integran las rentas en la transmitente ni se cambian los valores fiscales en la adquirente. No obstante, si la extinción por confusión de derechos de un préstamo genera renta en la entidad absorbente, dicha renta sí formará parte de su base imponible.
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