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The taxpayer asks whether a partial demerger can qualify for the special regime under Corporate Income Tax. The DGT rules that, for this to apply, the segregated assets must constitute an autonomous economic unit and a line of business previously identified within the transferring entity.
This ruling clarifies the strict requirements for tax-neutral demergers, emphasizing that the segregated assets must represent a distinct, pre-existing functional unit rather than just a collection of assets.
The tax team reviews your specific situation.
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