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A company has requested a ruling regarding a total demerger to segregate livestock and rural tourism activities, as well as to plan for family succession. The DGT has ruled that the operation may qualify for the special restructuring regime, provided it is carried out under commercial law and its primary purpose is not tax evasion or obtaining a tax advantage.
This ruling clarifies that structural changes driven by genuine business purposes, such as activity segregation or succession planning, can maintain tax neutrality under the special restructuring regime.
The tax team reviews your specific situation.
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