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V1858-24 ·6 August 2024 ·consulta-vinculante Medium impact
Tax

Variable fees of securitisation funds are included in net financial expenses based on their nature

A securitisation fund manager has enquired whether variable fees should be treated as financial income or financial expenses for the purpose of applying the deductibility limit under Article 16 of the Corporate Income Tax Act. The Directorate General for Taxes (DGT) has ruled that the portion of the fee that offsets financial income and expenses must be included in the calculation of net financial expenses.

In 6 key points

How it affects those involved

This ruling clarifies the accounting treatment of variable fees for securitisation funds, specifically regarding their impact on the net financial expense calculation used to determine tax deductibility limits.

Lifecycle

2024-08-06PublishedPublished 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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