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The taxpayer asks whether contributing an economic unit without including its real estate or all employees prevents the transaction from being classified as a non-monetary contribution of a branch of activity. The DGT rules that it is not necessary to contribute all elements if the activity can be carried out autonomously and under similar conditions.
This ruling provides clarity for companies seeking to restructure or transfer business units under special tax regimes without transferring property ownership.
The tax team reviews your specific situation.
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