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V0512-21 ·8 March 2021 ·consulta-vinculante Medium impact
Tax

Contribution of a line of business may qualify for special regime if it constitutes an autonomous economic unit

The taxpayer asks whether the non-monetary contribution of a line of business meets the requirements of the special regime under the Corporate Income Tax Act (LIS) and if valid economic reasons exist. The DGT indicates that the transaction could meet the requirements if the transferred assets allow the activity to be carried out autonomously and under similar conditions.

In 6 key points

How it affects those involved

Companies looking to restructure by transferring specific business lines must ensure the transferred assets are sufficient to maintain the activity's autonomy to benefit from tax neutrality.

Lifecycle

2021-03-08PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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