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The taxpayer asks whether the segregation of assets can qualify for the special partial spin-off regime. The DGT rules that, as there is no pre-existing separate organisation constituting a line of business, the transaction does not meet the requirements of Corporate Income Tax.
Companies attempting to restructure by segregating assets without a distinct, pre-existing business unit will not benefit from the tax advantages of the special spin-off regime.
The tax team reviews your specific situation.
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