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V2355-14 ·9 September 2014 ·consulta-vinculante Medium impact
Tax

A contribution of assets must constitute a branch of activity through a pre-existing autonomous organisation

A taxpayer has enquired whether the contribution of a rural estate for hunting purposes constitutes a branch of activity or a non-monetary contribution. The DGT indicates that to qualify as a branch of activity, there must be an organisation of material and human resources that allows for autonomous and habitual exploitation.

In 6 key points

How it affects those involved

This ruling clarifies the distinction between a non-monetary contribution and a branch of activity, requiring proof of an autonomous organisational structure for tax purposes.

Lifecycle

2014-09-09PublishedPublished 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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