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A rights exploitation professional enquires whether contributing their activity to a company may qualify for the LIS special regime. The DGT responds that it is possible if the contributed elements constitute an autonomous economic unit and the transaction is based on valid economic reasons, not merely tax advantages.
Question posed: Whether the described operation may qualify for the special tax regime under Chapter VII of Title VII of Corporate Income Tax Law 27/2014, of November 27.
The contribution of a line of business may benefit from the special regime if the segregated assets themselves allow for the development of an identifiable economic activity. In this case, the set of material and human elements for the exploitation of copyrights constitutes an autonomous economic unit. Furthermore, the motives for the operation, such as the rationalization of the structure or business management, are considered economically valid pursuant to Article 89.2 of the LIS.
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