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The taxpayer asks whether income from debt restructuring (fair value adjustments) should be treated as financial income when calculating the deductibility limit for financial expenses. The DGT rules that, as these are related to corporate indebtedness, they must be included in the calculation to prevent tax asymmetries.
This ruling clarifies that fair value gains arising from debt restructuring must be included in the calculation of net financial income, potentially reducing the amount of financial expenses that can be tax-deductible under interest limitation rules.
The tax team reviews your specific situation.
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