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The taxpayer inquired whether a spin-off operation could qualify for the special Corporate Tax regime. The DGT ruled that, to do so, the segregated assets must constitute a business line with its own prior organisation within the company.
This ruling clarifies the strict requirements for tax-neutral spin-offs, emphasizing that the assets must function as a distinct, pre-existing business unit to benefit from special tax treatment.
The tax team reviews your specific situation.
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