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V0013-24 ·13 February 2024 ·consulta-vinculante Medium impact
Tax

Tax neutrality cannot apply to a non-proportional total demerger without two distinct lines of business

A company operating two dental clinics intends to carry out a non-proportional total demerger to create two new entities, with each partner owning 100% of one clinic. The DGT ruled that the transaction cannot benefit from the special tax neutrality regime because the existence of two autonomous lines of business has not been proven.

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2024-02-13PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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