Court of Appeal Antwerp rules on pre-2008 requirements for exempt split-up

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 their design and manufacturing. The BVBA is split into two divisions. One of the new companies after th…