Skip to content
V1110-14 ·16 April 2014 ·consulta-vinculante Medium impact
Tax

Proposed contribution does not meet special branch activity rules without legal conditions met

A Spanish company asks whether it can contribute four UK buildings to a new local company under the special branch activity regime and whether it may benefit from dividend and foreign-source income exemption. The DGT responds that the operation does not qualify as a branch activity contribution and that exemption depends on meeting participation, residency, and economic activity requirements.

In 6 key points

Lifecycle

2014-04-16PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact