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V0124-25 ·7 February 2025 ·consulta-vinculante Low impact
Tax

Requirements for the application of the tax regime of the First Additional Provision of Law 10/2014 to subordinated perpetual bonds

The DGT confirms that subordinated perpetual debt instruments, meeting investment, listing and rights conditions, are covered by the special tax regime, even if the subsidiary shifts its fiscal residence to Spain.

In 6 key points

How it affects those involved

The ruling applies the special tax regime to subordinated perpetual debt instruments regardless of the subsidiary's fiscal residence, affecting tax treatment for cross-border debt structures.

Lifecycle

2025-02-07PublishedPublished 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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