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A query is made as to whether the contribution of a branch of activity from a community of property to a company may qualify for the special regime of Corporate Income Tax. The DGT determines that it is not a contribution of a branch of activity, but rather a contribution of ideal shares, and that only those who maintain at least 5% of the capital may apply the regime.
Question posed: Whether the contribution of all elements comprising the assets and liabilities (including potential credits and debts) related to its economic leasing activity can be included, in its consideration as a business activity under article 76.4 of the LIS, in the special tax regime provided for in section 2 of article 87 of chapter VII of title VII of the Corporate Tax Law.
The contribution of ideal shares from a community of property does not constitute a contribution of a branch of activity, but rather a special non-monetary contribution. To apply the special regime of Article 87.1 of the LIS, each contributor must maintain a participation of at least 5% in the receiving entity. Those members of the community with a share of less than 5% may not avail themselves of said regime. Furthermore, the community of property must carry out an economic activity and maintain accounting records in accordance with the Commercial Code.
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