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MEDIUM
FISCAL

Deductibility of participative loan interest depends on group affiliation

V2152-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V2152-25
Published
13 Nov 2025

Summary

The DGT clarifies that interest from a participative loan is not deductible if the lender and borrower belong to the same group of companies, even if the interest is accounted for.

In 6 key points

Lifecycle

2025-11-13PublishedPublished 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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