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A query was raised regarding whether debt forgiveness by a company's shareholders can be considered entirely as a contribution to equity. The DGT ruled that only the portion proportional to their shareholding constitutes a contribution, whereas any excess is treated as income for the company and a non-deductible expense for the shareholder.
This ruling clarifies the tax treatment of debt forgiveness, distinguishing between equity contributions and taxable income based on the shareholder's actual stake in the company.
The tax team reviews your specific situation.
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