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V1988-23 7 July 2023 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · neutralidad fiscal

Requirements for the application of the tax neutrality regime in the contribution of real estate

The DGT states that it is not possible due to lack of evidence that rental activity constitutes an economic activity or that commercial accounting is maintained.

The question raised

1.- Whether the proposed restructuring operation is subject to the special regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax and, specifically:

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