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A company owning two leased properties asks whether a non-proportional total split can be carried out under the special tax neutrality regime for succession planning. The DGT responds that the operation does not meet fiscal requirements as there were no previously distinct business lines in the transferring company.
The operation fails to meet fiscal requirements because no distinct business lines existed prior to the split, thus disqualifying it from the special tax neutrality regime for succession planning.
The tax team reviews your specific situation.
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