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The evidence behind it.
Purchase price allocation, trade-income contamination and share deal: RAIVA is designed to keep source passage and open question together. The tax assessment stays with professionals.
Memo: 80 %. Valuation report: 72 %.
Tax memo, section 3: building share 80 % of the €12.5m purchase price. Valuation report, appendix 2: building €9.0m, land €3.5m.
Possibly: selling charging power to third parties can be a trade and contaminate all of the partnership’s income.