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A query was raised regarding whether the segregation of shares from one entity into another can qualify for the special spin-off regime. The DGT indicates that this may apply provided the spun-off entity retains enough shares to maintain a majority interest in other entities and the transaction is driven by valid economic reasons.
This ruling provides clarity for corporate restructuring, allowing for more flexible share segregation under the special regime, provided majority control is maintained and the transaction is not purely for tax avoidance.
The tax team reviews your specific situation.
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