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A cooperative has requested a ruling on whether the profit derived from acquiring promissory notes at a price below their face value can be allocated using the installment transaction method. The Directorate General for Taxes (DGT) has ruled that this is not possible, as the transaction constitutes an acquisition rather than a transfer or the provision of services.
The ruling clarifies that the tax treatment for installment transactions is restricted to sales or service provisions, preventing taxpayers from using this method to defer the recognition of gains from discounted financial instruments.
The tax team reviews your specific situation.
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