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A real estate development company has requested a ruling regarding the nature of its activity, the validity of a merger with a leasing company, and the accounting treatment of a property. The DGT determines that the reasons for the merger may be economically valid and analyses the VAT treatment and the accounting classification of the property.
Question raised 1.- Whether company A should be considered a company that carries out a business activity for Corporate Income Tax purposes and, therefore, is not an entity dedicated to the mere management of real estate assets.
The merger may qualify for the special tax neutrality regime if it is carried out for valid economic reasons, such as the rationalization of activities, and not for fraudulent purposes. The real estate property, after having been leased, must be accounted for as investment property or tangible fixed assets and not as inventory. The contribution of the real estate property is subject to VAT as it is considered a mere transfer of assets without an autonomous organizational structure. Differentiated VAT sectors shall not be established if the deduction percentage for development and leasing does not differ by more than 50 points.
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