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V2176-24 ·10 October 2024 ·consulta-vinculante Medium impact
Tax

Interest on participating loans between group entities is not a tax-deductible expense

A real estate company has inquired whether interest from a participating loan provided by its majority shareholder—which has been recognised in the accounts as part of the value of its inventory—is tax-deductible. The Directorate General for Taxes (DGT) has ruled that, as the entities belong to the same group, these payments are considered dividends and do not constitute a tax-deductible expense.

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2024-10-10PublishedPublished 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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