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July 17, 2026
Article 97 outlines the consequences if the tax-neutral option under Article 96 is selected. The transfer of assets is not treated as a taxable 'disposal'. Instead, the company (transferee) is treated as if it were the original owner for the purposes of depreciation, balancing allowances, and balancing charges. The Tax Authority will make all necessary adjustments—including assessments, exemptions, or refunds—to ensure the transition is seamless. This 'successor' treatment ensures that the historical tax basis of the assets is preserved and that the company continues the depreciation schedule started by the establishment.
Article 97
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