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An architecture firm has requested clarification on whether splitting into two entities (one for services and another for real estate) qualifies for the special demerger tax regime. The Directorate General for Taxes (DGT) indicates that, provided commercial regulations are met and the allocation of shares is proportional, this regime may apply as long as valid economic reasons exist.
Companies undergoing structural reorganisations may benefit from tax neutrality if they can demonstrate that the split is driven by genuine economic objectives rather than purely tax-driven motives.
The tax team reviews your specific situation.
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