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The DGT confirms that a merger between two companies held by the same shareholders may be treated as tax-neutral if it meets the conditions in Chapter VII of Title VII of the LIS and the objective is not fraud.
Question raised
If the merger is carried out under Royal Decree-law 5/2023 and complies with Article 76.1 of the LIS, the tax neutrality regime may be applied. In this case, income from the transfer or the cancellation of shares shall not be integrated, and the values and seniority of the assets shall be maintained. The absorbing company shall subrogate into the negative tax bases within the legal limits. The regime shall not apply if the primary objective is tax fraud or evasion.
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