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A company proposes to contribute immovable property to another entity with the intention of carrying out a financial spin-off of the received shares. The DGT determines that the operation cannot benefit from the special IS regime because the contribution of immovable property does not constitute a business activity and the structure aims to avoid direct tax on asset transfer.
Cuestión planteada 1º) Si las operaciones descritas pueden acogerse al régimen fiscal especial previsto en el Capítulo VII del Título VII de la Ley 27/2004, de 27 de noviembre, del Impuesto sobre Sociedades.
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