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V0191-14 ·28 January 2014 ·consulta-vinculante Medium impact
Tax

Full debt forgiveness between parent and subsidiary generates no tax effects

A Spanish subsidiary asks whether forgiving a debt to its 100% German parent company, recorded accountably as a contribution of own funds, results in taxable income. The DGT responds that, due to the 100% parent-subsidiary relationship, the transaction is a patrimonial transfer with no tax consequences under Corporate Income Tax.

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2014-01-28PublishedPublished 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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