On 5 May 2012, the Court of Appeal gave its decision (recently published) in the case of X BVBA v. the Belgian tax administration concerning the pre-2008 requirements for an exempt split-up. Details of the case are summarized below.
(a) Facts. The case concerned a partial split-up of a limited liability company (BVBA) carrying out the placing of doors, windows and stairs, and thei…