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V0152-17 ·24 January 2017 ·consulta-vinculante Medium impact
Tax

Income and derivative expenses losing hedge accounting status are not included in net financial expenses

A company has enquired whether the results of a financial derivative that loses its hedge accounting status should be included in the calculation of net financial expenses for the deductibility limit. The DGT has ruled that, upon losing such status, these amounts are decoupled from the hedged debt and must not be counted towards the limit set out in Article 16 of the Corporate Income Tax Act.

In 6 key points

How it affects those involved

This ruling clarifies that derivative gains or losses no longer qualifying for hedge accounting do not contribute to the net financial expenses used to determine the tax deductibility limit for interest expenses.

Lifecycle

2017-01-24PublishedPublished 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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