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A query was raised regarding whether a total demerger of a real estate company can apply the special regime under the Corporate Income Tax Act (LIS) and if valid economic reasons exist. The DGT indicates that if carried out under the Structural Changes Act and if the allocation of values is proportional, said regime could apply, provided it is not intended for tax fraud or evasion.
Companies undergoing total demergers must ensure compliance with the Structural Changes Act and demonstrate proportional value allocation and valid economic motives to benefit from tax neutrality.
The tax team reviews your specific situation.
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