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A consulting company proposes the absorption merger of a wholly-owned subsidiary. The DGT states that under the commercial framework of Royal Decree-Law 5/2023, the transaction may apply the corporate tax neutrality regime and be exempt from the ITPAJD.
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 of Chapter VII of Title VII of the LIS may be applied. In this case, income from the cancellation of the participation or from transfers shall not be recognized, and the values and seniority of the received elements shall be maintained. Negative tax bases may be offset according to the limits of Articles 84 of the LIS and DT 16th. Regarding the ITPAJD, the operation shall be not subject to the corporate operations modality and exempt in the modalities of onerous asset transfers and documented legal acts.
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