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A property development company has enquired whether the contribution of a shopping centre's assets and liabilities to another entity can qualify for the special regime for the contribution of business lines. The Directorate General for Taxes (DGT) indicates that this is possible provided the assets constitute an economic unit capable of operating independently and there are valid economic reasons for the transaction.
Question posed: Whether the application of the special regime under Chapter VIII of Title VII of the recast text of the Corporate Income Tax Law is appropriate for the operations presented. And whether the alleged reasons are considered economically valid for these purposes.
To apply the special regime for non-monetary contributions of business lines, the transferred assets must constitute an autonomous economic unit that allows for the development of an economic activity within the acquiring company. Likewise, the activity must have previously existed in the transferring company to allow for the identification of the asset pool. The operation must comply with requirements such as a minimum participation of 5% in equity and must not have the primary objective of tax fraud or evasion, and must be based on valid economic reasons.
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