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A query was raised regarding whether a special purpose vehicle (SPV) created by a credit institution can be classified as a credit institution to avoid the financial expense deductibility limit set out in Article 20 of the TRLIS. The DGT ruled that if the SPV is part of a consolidable group and is subject to Bank of Spain supervision and the obligations of Law 13/1985, it may be treated as a credit institution.
The tax team reviews your specific situation.
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