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A company with two 50% shareholders seeks to carry out a non-proportional total split to establish two new companies, each with a 100% shareholder, without incurring capital gains tax. The DGT states that for fiscal neutrality, the segregated assets must form autonomous business units.
The operation must ensure that the segregated assets constitute independent business units to avoid capital gains tax, ensuring fiscal neutrality.
The tax team reviews your specific situation.
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