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A self-employed restaurant operator has enquired whether the special asset contribution regime can be applied when transferring their business to a company. The Directorate-General for Taxes (DGT) indicates that this is possible provided the set of elements constitutes a branch of activity capable of operating independently.
Question posed: Whether the application of the special regime of Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law is appropriate for the operation presented. And whether the alleged reasons are considered economically valid for these purposes.
To apply the special regime, the contribution must constitute a line of business, understood as a set of assets that form an autonomous economic unit capable of operating by its own means. This concept requires a differentiated business organization that allows for the identification of a set of assets destined for an autonomous economic exploitation. The regime shall not apply if the primary objective is tax fraud or evasion, or if the operation lacks valid economic reasons beyond the tax advantage.
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