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V0368-14 ·13 February 2014 ·consulta-vinculante Medium impact
Tax

Tax treatment of subordinated debt conversion depends on whether the arbitral award is successful

The taxpayer inquires about the tax treatment of converting subordinated bonds into shares and the impact of a potential arbitral award. The DGT rules that if the award is unsuccessful, a return on movable capital is generated from the repurchase, alongside a capital gain or loss on the shares. If the award is successful, a return on movable capital is generated based on the difference between the amount to be repaid and the original subscription value.

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2014-02-13PublishedPublished 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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