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A query was raised regarding whether a total demerger of a company can apply the special regime for mergers and demergers. The DGT indicates that if the requirements of the Corporate Income Tax Act (LIS) are met and the allocation of values is proportional, it could be applicable, provided its primary purpose is not tax advantage.
Companies undergoing total demergers must ensure they meet all LIS requirements and possess valid economic justifications to benefit from the special tax regime and avoid being flagged for tax avoidance.
The tax team reviews your specific situation.
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