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A company inquired whether a merger followed by a non-monetary contribution of a business activity could qualify for the special regime under the LIS. The DGT replied that this is possible provided the business activity constitutes an autonomous economic unit and the operation does not have the primary objective of tax fraud or evasion.
Question posed: Whether the proposed operation may qualify for the special regime provided for in Chapter VII of Title VII of the Corporate Income Tax Law, and whether the economic motives adduced are considered valid for these purposes.
For a non-monetary contribution of a business line to qualify for the special regime, the transferred assets must constitute an autonomous economic unit capable of operating by its own means. The activity must have previously existed within the transferor with a distinct business organization. Furthermore, the operation must not have tax advantage as its primary objective, but rather valid economic motives such as the restructuring or rationalization of activities. The existence of the business line and the validity of the economic motives are matters of fact that the Administration may verify.
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