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A query was raised regarding whether the contribution of members' participation shares in a community of property to a company can benefit from the special regime for non-monetary contributions. The DGT ruled that, as it does not constitute a business activity in itself, the contribution of an ideal share is considered a special non-monetary contribution subject to the regime under Article 94.1 of the TRLIS.
Question posed: Whether the described transaction may qualify for the special tax regime under Chapter VIII, Title VII of the Recast Text of the Corporate Income Tax Law approved by Royal Legislative Decree 4/2004, of March 5.
The contribution of a co-owner's ideal share is not a contribution of a line of business, but rather a special non-monetary contribution pursuant to Article 94.1 of the TRLIS. To qualify for the special regime, each contributor must individually satisfy the requirements of entity residence, a minimum participation of 5% in equity, and allocation to economic activities with commercial accounting. Furthermore, the transaction must respond to valid economic reasons and not have the primary purpose of obtaining a tax advantage.
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