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A company has requested a ruling on the tax treatment of convertible bonds, specifically regarding the deductibility of issuance costs and the treatment of their redemption or repurchase. The DGT has determined that, due to their commercial nature, these bonds are liability instruments rather than equity instruments.
This ruling clarifies the tax classification of hybrid instruments, confirming that convertible bonds are treated as debt, allowing for the deduction of issuance costs through amortisation and affecting the tax treatment of interest and repayments.
The tax team reviews your specific situation.
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