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A query was raised regarding whether a total demerger of a company, where shareholders receive shares in unequal proportions, can qualify for the special Corporate Tax regime. The DGT ruled that for this to apply, the segregated assets must constitute autonomous business lines that were previously identified within the transferring company.
Companies undertaking total demergers must ensure that the assets being split off are clearly defined as autonomous business lines to benefit from tax neutrality; otherwise, the transaction may be treated as a taxable capital gain.
The tax team reviews your specific situation.
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