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V0118-17 ·23 January 2017 ·consulta-vinculante Medium impact
Tax

Debt forgiveness between a parent company and its wholly-owned subsidiary does not generate tax income or expenses

A company sought clarification on the tax treatment of debt forgiveness carried out by its parent company, which holds 100% of its capital. The DGT ruled that this transaction does not generate tax income or expenses, provided that the tax value of the credit and the debt are identical.

In 6 key points

How it affects those involved

This ruling provides legal certainty for intra-group debt restructuring, confirming that such operations are tax-neutral when the tax values align.

Lifecycle

2017-01-23PublishedPublished 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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