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An individual has enquired whether they can contribute their property rental activity to a new company under the special regime of Corporate Tax. The DGT has ruled that this is possible if the set of elements constitutes a business line capable of operating independently and if valid economic reasons exist.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the consolidated text of the Corporate Income Tax Law is appropriate for the operation presented. And whether the alleged motives are considered economically valid for these purposes.
To apply the special regime, the contribution must constitute a branch of activity, understood as a set of assets that form an autonomous economic unit capable of operating by its own means. This concept should not be strictly equated to the economic activity under Personal Income Tax (IRPF), but rather analyzed according to whether a differentiated business organization exists. Furthermore, the operation must not have fraud or tax evasion as its primary objective, and must be based on valid economic motives.
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