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V1849-24 ·2 August 2024 ·consulta-vinculante Medium impact
Tax

Forgiveness of an intercompany loan within a coordination group does not generate tax income or expenses

A query was raised regarding whether the forgiveness of a loan between three companies held by the same partners generates tax effects. The DGT has determined that, as these companies belong to a coordination group, the transaction is treated accounting-wise as a distribution and contribution of funds, with no impact on the tax base.

In 6 key points

How it affects those involved

The ruling clarifies that intra-group debt forgiveness within a coordination group is neutral for tax purposes, as it is viewed as a movement of equity rather than a taxable event.

Lifecycle

2024-08-02PublishedPublished 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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