Uni 03-05-2018 - Guidance on tax policy for enterprise separation

Official letter 1064/TCT-KK dated 29 March 2018 of GDT guidance on tax policy for enterprise separation:

In case, after splitting the enterprise, the separated company still has the VAT amount not yet fully deducted and the overpaid CIT amount, the separated company does not apply for reimbursement but request to transfer the part to the separated company for clearing. VAT arising from business activities of the separated company. Accordingly, for the deductible VAT amount to be divided in proportion to the value of assets transferred to the separated company and the separated company, the overpaid CIT shall be split in accordance with the resolution of the Company