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A consultancy firm proposes the non-monetary contribution of a machine to its subsidiary to specialise production and optimise resources. The DGT states that the transaction may qualify for the special neutrality regime if residence and minimum shareholding requirements are met.
FIRST.- Confirmation that the non-monetary contribution operation, as previously described, would objectively fall within the special regime provided for in Chapter VII of Title VII of the LIS. SECOND.- Confirmation that the economic reasons stated in this consultation are sufficient for the purpose of considering the subjective requirement met for the classification of the non-monetary contribution within the scope of the special tax neutrality regime, in accordance with Article 89.2 of the LIS
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