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The DGT clarifies that internal patent assignments do not trigger the LIS article 23 reduction at the time of transfer, but only when the transaction is effectively carried out towards third parties.
Question raised 1º) Whether, given that the assets subject to transfer are eligible for the reduction provided for in Article 23 of Law 27/2014, of November 27, on Corporate Income Tax, the aforementioned article would be applicable, considering that the transfer is made in favor of an entity belonging to the tax consolidation group and the subsequent sale to third parties of the assets for the production of which the said patents will be used.
En operaciones de consolidación fiscal, los ingresos por la cesión de intangibles (art. 23 LIS) se incorporarán a la base imponible del grupo cuando se entiendan realizados frente a terceros, según el artículo 65.2 de la LIS. No procede la reducción en cesiones circulares donde la creadora original es también la cesionaria. Para activos desarrollados por la entidad tras la reorganización, la reducción se aplicará en el periodo en que la cesión se materialice frente a terceros.
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