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A query was raised regarding whether a partial spin-off followed by a share exchange could qualify for the special Corporate Tax regime. The DGT ruled that, based on the facts, the assets to be transferred do not appear to constitute an autonomous line of business with its own prior organisation.
Companies attempting to restructure through spin-offs must ensure that the assets being transferred function as a distinct, organised line of business prior to the transaction to benefit from special tax treatments.
The tax team reviews your specific situation.
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