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A taxpayer asks whether contributing rented immovable property to a company constitutes an economic activity subject to fiscal neutrality. The DGT responds that shares in proindiviso are non-monetary contributions and not an economic activity, and that the requirement of economic activity is not met when an employee is shared between personal and community property.
Cuestión planteada 1. Si la aportación del bloque patrimonial aportado a la entidad A, S.L., constituye una rama de actividad para la entidad adquirente, y por tanto, constituye una operación de aportación no dineraria de rama de actividad susceptible de 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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