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A company has enquired whether segregating its cosmetics manufacturing branch into a new entity qualifies for the special regime under the Corporate Income Tax Act. The DGT indicates this is possible provided the transferred assets constitute an autonomous economic unit and the transaction is supported by valid economic reasons.
Question raised 1) Whether the described transaction could qualify for the special tax regime provided for in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The transaction is classified as a non-monetary contribution of a line of business if the contributed assets allow for the development of an autonomous economic activity within the acquirer. To apply the special regime, the activity must have previously existed in the transferor and the transaction must not have the primary purpose of fraud or tax advantage. In this case, the entry of an industrial partner is considered a valid economic motive. The acquiring entity may subrogate itself into the negative tax bases generated by the transferred line of business.
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