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The taxpayer asks whether contributing an economic unit without including its real estate or all employees prevents the transaction from being classified as a non-monetary contribution of a branch of activity. The DGT rules that it is not necessary to contribute all elements if the activity can be carried out autonomously and under similar conditions.
Question raised 1.- Whether the set of contributed elements can be classified as a business unit for the purposes of Article 76 of Law 27/2014, of November 27, on Corporate Income Tax, or whether the failure to contribute both the real estate and some or all of the employees comprising the business prevents its classification as such.
For a contribution to be considered a business unit, the assets must constitute an autonomous economic unit capable of operating by its own means. The absence of certain elements, such as real estate, does not prevent this classification provided they are not essential or relevant to the development of the business operation. The activity must be capable of being carried out within the acquiring entity under economic conditions equivalent to those of the transferring entity.
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