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A company has requested clarification on whether its related-party creditors can deduct expenses arising from a judicial debt forgiveness, and how the debtor should treat income from debt forgiveness and deferrals. The DGT refused to rule on the creditors' position as they did not submit the consultation, but it did explain the accrual rules for the debtor.
The ruling clarifies the tax treatment of debt forgiveness and deferrals for the debtor, while reinforcing the procedural requirement that interested parties must submit their own consultations to receive a binding ruling.
The tax team reviews your specific situation.
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