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V5038-26 15 June 2026 · SG de Impuestos sobre las Personas Jurídicas Analysis pending
IRPF · aportación no dineraria

Possibility of applying the tax neutrality regime to the contribution of community of property quotas

Siblings have consulted whether they can apply the special regime for non-monetary contributions (Art. 87.1 LIS) when contributing their shares in a community of property to a company. The DGT ruled that this is not applicable because the leasing of real estate without employees does not constitute an economic activity, thereby preventing the fulfillment of the requirements regarding the allocation of assets to an activity.

Analysis pending. This ruling has been identified and indexed by the automatic ingestion system. BMC's team will complete the plain-language analysis within 24 hours. You may access the official source in the meantime.

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