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A company enquired whether the transfer of pallets and containers in Spain, as part of an international merger, could be considered an exempt transaction under the transfer of a business rule. The DGT ruled that, as there is no autonomous economic unit, the transaction is subject to VAT and the purchaser must apply the reverse charge mechanism.
Question posed: Liability for Value Added Tax regarding the described merger operation.
The transfer of goods does not constitute an autonomous economic unit if it is not accompanied by an organizational structure of material and human production factors. In this case, the delivery of pallets and containers is considered a mere transfer of goods subject to VAT. Since neither the transferor nor the acquirer is established in Spain, the acquirer shall be the taxable person under the reverse charge mechanism. Due to this status as a taxable person, the company will not be able to use the refund procedure under Article 119 and must use the general procedure under Article 115.
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