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A taxpayer asks whether contributing their rental business to a company and the subsequent merger of two companies can apply the special IS regime, VAT and IIVTNU exemption, and income tax neutrality. The DGT responds that this is possible if an autonomous economic unit with own resources is contributed and valid economic reasons exist.
Question posed: Whether the described operations of contribution of a business line and merger between companies A and B may qualify for the special tax regime established in Chapter VII of Title VII of Law 27/2014, of November 27, on Corporate Income Tax.
The contribution of a business line qualifies for the special regime if the assets constitute an autonomous economic unit with an organization of material and human resources. The merger may qualify for the regime if it is carried out within the commercial sphere and responds to valid economic motives, rather than solely to a tax advantage. Regarding VAT, the transfer shall not be subject to tax if an organizational structure that allows for the development of the activity is transferred. For the ITP/AJD, non-applicability depends on the real estate being integrated into a business line.
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