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A query was raised regarding whether holding companies that indirectly carry out credit activities through their participation in credit institutions can be treated as financial institutions to bypass the limit on the deductibility of financial expenses. The DGT ruled that if they are part of a consolidable group and are subject to Bank of Spain supervision and solvency regulations, they may be treated as credit institutions.
This ruling provides potential tax relief for holding companies within banking groups, allowing them to potentially bypass certain restrictions on financial expense deductibility if they meet specific regulatory and consolidation criteria.
The tax team reviews your specific situation.
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