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A company asks whether a non-proportional total split of its assets (vessels and rented garages) qualifies for the fiscal neutrality regime. The DGT responds that, based on the facts, the assets are isolated and do not constitute autonomous business units, so the regime does not apply.
The fiscal neutrality regime does not apply to non-proportional total splits if the segregated assets do not form autonomous business units.
The tax team reviews your specific situation.
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