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V0985-14 ·7 April 2014 ·consulta-vinculante Medium impact
Tax

Branch transfers from parent not taxable if non-recoverable

A Norwegian entity's Spain branch asks about the tax treatment of bank transfers from its parent with no specific purpose. The DGT states that if transfers are non-recoverable, they are considered own funds and do not generate taxable income.

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2014-04-07PublishedPublished 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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