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V2346-24 ·12 November 2024 ·consulta-vinculante Medium impact
Tax

Deterioration of loans to Mexican subsidiary not deductible until liquidation, when loss is deductible under art. 21.8 LIS

A Spanish company with a 95% Mexican subsidiary proposes the dissolution of an inactive subsidiary. The granted loans are fully impaired accountably. The DGT distinguishes between the impairment phase (not deductible due to related parties without liquidation opening) and the extinction phase, when prior adjustments are reversed and the final loss is recognised, making the negative income deductible under art. 21.8 LIS.

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2024-11-12PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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