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An educational group requested a ruling on whether separating its teaching centres to create new companies constitutes a partial spin-off. The DGT ruled that, to qualify for the special tax regime, the transferred assets must constitute a line of business with its own organisation prior to the transaction.
Companies planning restructuring through spin-offs must ensure that the assets being transferred are structured as an independent line of business with its own organisational setup to benefit from special tax treatment.
The tax team reviews your specific situation.
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