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A coachbuilding company inquired whether it could perform a partial spin-off to transfer its cash reserves to a new company (SICAV) and qualify for the special tax regime. The Directorate General of Taxes (DGT) ruled that cash reserves do not constitute a separate line of business.
Companies attempting to spin off liquid assets or cash reserves into separate entities to benefit from tax advantages will not be permitted, as these assets do not qualify as an independent business unit.
The tax team reviews your specific situation.
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