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11.1. Direct and Indirect Tax Consequences of Re-Organizations

In general, the transfer of assets at market value may create a taxable gain / (loss) for corporate income tax, and the transferor must invoice VAT at the standard rate on the transferred assets.

Transfers of assets are conducted at book value for a tax-neutral merger, consolidation, or business spins off. Transfer at book value is available only upon an approval from the Tax Authority. The approval is generally subject to the condition that a business purpose test is met.

The facility for business spins-offs is available for Initial Public Offering plans and some requirements must also be satisfied.