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The applicant asks whether a demerger of their assets can qualify for the special Corporate Tax regime and if valid economic reasons must exist. The DGT indicates that, provided commercial regulations are met, the special regime may apply as long as its primary purpose is not tax evasion or tax advantage.
Companies planning structural reorganisations must ensure that demergers are driven by genuine economic motives rather than purely tax-driven objectives to qualify for special tax treatment.
The tax team reviews your specific situation.
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