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An individual leasing business premises has enquired whether they can contribute said activity to a new company under the special Corporate Tax regime. The DGT has ruled that this is possible if the contributed assets constitute a line of business that operates independently.
Question posed: Whether the application of the special regime under Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law is appropriate for the transaction presented. And whether the alleged reasons are considered economically valid for these purposes.
To apply the special regime, the segregated assets must constitute an autonomous economic unit capable of operating by its own means. The concept of a branch of activity should not be strictly equated to the concept of economic activity under Personal Income Tax, but rather analyzed according to whether an autonomous exploitation exists from an organizational standpoint. Furthermore, the transaction must respond to valid economic reasons and not have the primary purpose of obtaining a tax advantage.
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