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V2371-23 ·4 September 2023 ·consulta-vinculante Medium impact
Tax

A loss from an accordion operation cannot be tax deductible if it does not generate an accounting entry in the shareholder

The consultant asks whether the termination of a purchase and sale agreement and a simultaneous capital reduction and increase operation (accordion operation) in its investee generate extra-accounting adjustments in Corporate Income Tax. The DGT determines that the accordion operation must not produce a tax impact if it does not originate an accounting entry in the shareholder.

Lifecycle

2023-09-04PublishedPublished 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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