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A consulting entity asks whether the contribution of physical property by individuals can qualify for the special non-monetary contribution regime. The DGT responds that this is not possible because the assets appear to come from personal wealth and are not linked to any economic activity.
Question posed: Whether the described operation may qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
To apply the special regime for non-monetary contributions, the assets other than shares or participations contributed by EU residents must be used for economic activities. In this case, as the properties derive from the personal assets of the applicants without prior use for an economic activity, the requirements of Article 87.d) of the LIS are not met.
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