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V0192-14 ·28 January 2014 ·consulta-vinculante Medium impact
Tax

Forgiveness or capitalisation of a loan between subsidiaries of the same group does not generate tax income under specific conditions

A company inquired whether the forgiveness or capitalisation of a participative loan, which is recorded in accounts as income or equity, has tax consequences. The DGT responds that if both companies are indirectly 100% owned by the same parent, the transaction does not generate taxable income or expenses.

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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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