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The consultant proposes a series of linked transactions (non-cash contribution, financial split, and share exchange) to restructure their business. The DGT finds that although economic motives appear valid, the combination of contribution and financial split achieves effects equivalent to separating non-business assets, which is not covered by the special regime.
Companies attempting to restructure through linked transactions that effectively separate non-core assets may not benefit from the special regime, as such actions are deemed outside its scope.
The tax team reviews your specific situation.
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