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V1861-24 ·6 August 2024 ·consulta-vinculante Medium impact
Tax

Variable fees in securitisation funds are treated according to the nature of the income and expenses they offset

A securitisation fund manager has requested clarification on whether variable fees should be classified as financial income or financial expenses for the purpose of applying the financial expense deductibility limit. The DGT has ruled that variable fees must follow the nature of the items they offset (financial or non-financial) to prevent fiscal asymmetries.

In 6 key points

How it affects those involved

This ruling clarifies the tax treatment of variable fees in securitisation funds, ensuring that their classification aligns with the underlying transactions to maintain consistency in the application of financial expense deductibility rules.

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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