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A company asks whether a partial financial spin-off and subsequent share exchange may apply to the special tax neutrality regime of the Corporate Income Tax. The DGT states that this is possible provided that commercial and LIS requirements are met, and that the primary objective is not fraud or tax evasion.
Companies considering partial financial spin-offs or share exchanges may benefit from tax neutrality under certain conditions, provided the transactions comply with commercial and legal requirements and are not primarily aimed at tax avoidance.
The tax team reviews your specific situation.
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