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A real estate company has requested a ruling regarding the application of the special demerger regime, the treatment of tax loss carryforwards, the classification of the resulting entities, and exemptions from VAT and ITPAJD. The DGT indicates that a demerger could be tax-neutral if justified by economic reasons and analyses VAT liability on the basis that it does not constitute an autonomous economic unit.
The tax team reviews your specific situation.
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