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A query was raised regarding whether the contribution of a rural estate and its components by a natural person can qualify for the special regime for asset contributions under Corporate Tax. The Directorate General for Taxes (DGT) indicates that, although the assets may constitute a line of business, the transaction cannot have tax advantage as its primary purpose without justifying economic motives.
Question raised 1) Whether the described transaction may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
For a contribution by a natural person to qualify for the special regime, the assets must constitute an autonomous economic unit capable of operating by its own means. However, the regime does not apply if the primary objective of the transaction is tax fraud or evasion, or if it is not carried out for valid economic reasons such as the restructuring or rationalization of activities. In the specific case, as an economic motivation additional to tax efficiency has not been proven, the special regime is not applicable.
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