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V0047-26 ·13 January 2026 ·consulta-vinculante Medium impact
Tax

Interests of a participative loan between non-group companies are income for lender and deductible expenses for borrower

A company (X) granted capital to another (Y) via a participative loan whose interest depends on the profit from the sale of plots. The DGT examines whether these interests constitute remuneration of own funds or can be deducted as financial expenses.

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2026-01-13PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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