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A company enquired whether, when integrating a subgroup into a larger tax group, the operating profit used to apply the financial expense limit must include eliminations and adjustments arising from transactions with both the subgroup entities and the new tax group entities. The DGT ruled that such transactions must indeed be taken into account to determine the operating profit.
This ruling clarifies the calculation of operating profit for the limitation of tax-deductible financial expenses within a tax group, ensuring that intra-group transactions are correctly adjusted to reflect the economic reality of the consolidated entity.
The tax team reviews your specific situation.
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