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A company has enquired whether the non-monetary contribution of its biofertiliser manufacturing division can qualify for the special business restructuring regime. The Directorate General for Tax (DGT) states that this is possible provided that the contributed assets constitute an autonomous economic unit and the transaction is supported by valid economic reasons.
This ruling clarifies the conditions under which non-monetary contributions of specific business divisions can benefit from tax advantages under the business restructuring regime, emphasizing the need for economic substance and autonomy.
The tax team reviews your specific situation.
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