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The query asks whether a merger between two companies held by the same shareholders may qualify for tax neutrality. The DGT responds that it is possible if the requirements of the LIS are met and the transaction does not have fraud or tax evasion as its primary objective.
Cuestión planteada
Si la fusión se realiza al amparo del Real Decreto-ley 5/2023 y cumple el artículo 76.1 de la LIS, puede acogerse al régimen de neutralidad fiscal. Esto implica que no se integrarán rentas en la entidad transmitente ni en la adquirente, y los socios residentes en España tampoco integrarán rentas por la atribución de valores. No obstante, el régimen no se aplicará si el objetivo principal es el fraude o la evasión fiscal, o si se busca una ventaja fiscal espuria.
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