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An entity inquired whether the operation of a hotel/spa and a restaurant could be considered independent business branches for a partial spin-off. The DGT ruled that, provided they possess their own organisation and resources, they may qualify as business branches, even in cases involving the leasing of real estate.
This ruling provides legal certainty for companies seeking to undergo partial spin-offs by clarifying the criteria for defining autonomous business branches, specifically regarding the requirement for independent organisational and material resources.
The tax team reviews your specific situation.
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