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July 17, 2026
Article 96 gives both the transferor (establishment) and the transferee (company) the right to choose whether to apply the specialized 'tax-neutral' transfer rules or the standard disposal provisions of the Law. To exercise this option, a formal notice must be sent to the Authority within six months of the end of the tax year in which the transfer occurred. This must be done before the owner disposes of any shares received in exchange for the business. Once this choice is made, it is legally irrevocable, providing certainty for the tax treatment of the reorganization.
Article 96
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