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Members of a community of property intend to contribute their ideal share and the assets of their rental activity to a company. The DGT analyses whether this operation qualifies as a contribution of a branch of activity or as a special non-monetary contribution, and its impact on other taxes.
Question raised 1) Whether the described operation may qualify for the special tax regime of Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
The contribution of each co-owner's ideal share is considered a special non-monetary contribution under Art. 94.1 TRLIS, provided that the requirements of minimum 5% participation and allocation to economic activity are met. As it is an autonomous economic unit, the transfer is not subject to VAT pursuant to Art. 7.1 of Law 37/1992. The operation constitutes a restructuring, therefore it is not subject to the corporate operations modality of the ITPAJD and is exempt in its other modalities. The exception of the Securities Market Law does not apply as these are newly issued shares.
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