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A company proposes a total demerger to separate its industrial activity from its real estate holdings. The DGT analyses the application of the special Corporate Tax regime, VAT non-applicability due to the transfer of an economic unit, and the taxation implications regarding Personal Income Tax, Transfer Tax, and Stamp Duty, and Wealth Tax on Large Fortunes.
This ruling clarifies the tax conditions for demergers involving the separation of assets, specifically regarding the requirements for VAT exemption and the application of special Corporate Tax rules when transferring an autonomous economic unit.
The tax team reviews your specific situation.
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