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A real estate leasing company proposes a full split, transferring its assets to two newly created entities, allocating ownership shares proportionally to existing partners. The DGT confirms the operation meets the requirements of article 76.2.1.a) of the Income Tax Law (LIS) for the tax neutrality regime, without needing to prove that the split assets constitute business branches, due to the proportional allocation. Family continuity and orderly succession are valid economic grounds under article 89.2 of the LIS.
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