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A query was raised regarding whether a total demerger operation can apply the special Corporate Tax regime. The DGT indicates that, provided legal requirements are met and the allocation of values is proportional, it could be applied as long as its primary purpose is not to obtain a tax advantage.
Companies undergoing restructuring must ensure that demergers are driven by genuine economic motives rather than tax avoidance to benefit from the special regime.
The tax team reviews your specific situation.
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