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V1511-14 ·9 June 2014 ·consulta-vinculante Medium impact
Tax

Linked participative loans must be valued at market value

A company seeks advice on the tax treatment of a participative loan to a non-resident administrator or shareholder. The DGT clarifies that if a relationship exists, the Administration may value the transaction at market value and assess taxation based on the lender's residency.

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2014-06-09PublishedPublished 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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