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V1756-23 ·16 June 2023 ·consulta-vinculante Medium impact
Tax

Possibility of applying special contribution regime for activity branch without personal loan transfer

A natural person asks whether they can contribute their restaurant activity to a limited liability company under the LIS special regime, even if a personal loan cannot change ownership. The DGT confirms this is possible if the assets form an autonomous economic unit, but the company cannot deduct expenses from such a loan.

In 6 key points

How it affects those involved

Businesses may contribute their activity to a limited liability company under the special regime if the assets form an autonomous economic unit, but loan-related expenses cannot be deducted.

Lifecycle

2023-06-16PublishedPublished 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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