Administrative circular on spin-off transactions
On April 20th, 2020, the Belgian Tax Administration issued the circular 2020/C/55 further detailing the tax treatment of spin-off transactions according to article 264, first paragraph, 4° of the BITC 92. Context As a reminder, the so-called spin-off transactions are not demerger transactions nor transactions assimilated to a demerger, as defined by article 2, §1,