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A pharmaceutical company inquired whether it could apply the incentive under Article 23 of the Corporate Income Tax Act for licensing know-how following a partial demerger. The Directorate General for Taxes (DGT) ruled that the transfer of information regarding industrial and commercial expertise constitutes know-how and qualifies for the reduction, and that the entity resulting from the demerger subrogates into this right.
The tax team reviews your specific situation.
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