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A Spanish resident entity asks whether the transfer of a business to another company can qualify for the special regime of asset contribution. The DGT states that the requirements of participation and residence are met, provided the operation is not primarily aimed at obtaining a fiscal advantage.
Cuestión planteada 1º) Si la operación descrita en virtud de la cual la entidad T transmite a S el negocio de DM podría acogerse al régimen fiscal especial previsto en el Capítulo VII del título VII de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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