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A wine company has requested clarification on whether the segregation of estates and shares in another company qualifies for the special demerger regime. The Directorate-General for Taxes (DGT) has ruled that the real estate asset portion does not constitute a distinct line of business and, therefore, does not qualify for the special regime.
Companies attempting to demerge real estate assets without a functional business structure cannot benefit from the tax advantages of the special demerger regime.
The tax team reviews your specific situation.
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