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V0758-15 ·9 March 2015 ·consulta-vinculante Medium impact
Tax

Capitalisation of debts between 100% sister companies does not generate taxable income under certain conditions

A query was raised regarding whether the assignment of credits, their capitalisation through capital increases, and the subsequent acquisition of treasury shares within a tax consolidation group generate taxable income or require adjustments. The DGT ruled that, provided certain conditions regarding fiscal value and shareholding are met, these operations do not generate taxable income and therefore do not require adjustments in the tax consolidation process.

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2015-03-09PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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