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Partners of a civil society intend to contribute their share of a community of property to a new limited company. The DGT ruled that the transaction does not qualify for the special regime because the leasing of machinery does not constitute an economic activity.
Question posed: Whether the described restructuring operation can be qualified as a non-monetary contribution in accordance with the provisions of the special regime under Chapter VIII of Title VII of the TRLIS.
To benefit from the special regime under Article 94 of the TRLIS through the contribution of an ideal share, the assets must be used for economic activities. In this case, the leasing of machinery by the civil society is not considered an economic activity as it does not possess sufficient material or human resources. Therefore, the requirements of Article 94.1.d) of the TRLIS are not met.
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