Deferral of tax on the transfer of assets (Article 104)

Mechanism

Section 104 allows the transfer of assets to a new legal entity (company) without a tax event, provided that the transferor receives only shares.

Conditions

  • Accepting shares only (not cash)
  • Continued possession of assets through the company
  • Approval of the Director of the Tax Authority
  • Maintaining the original tax base

Important Note: The information on this website is for general informational purposes only and does not constitute professional tax advice. Consult a qualified tax advisor before making financial decisions.