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V2647-21 ·3 November 2021 ·consulta-vinculante Medium impact
Tax

To qualify for the special regime for non-proportional total demergers, assets must constitute business lines

A query was raised regarding whether a total demerger, where shareholders receive shares in proportions different from their original holdings, can apply the special regime under the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) indicates that, as it is a non-proportional demerger, it is a requirement that the spun-off assets constitute autonomous business lines.

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2021-11-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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