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Same as V2519-24: partners A (22.5%) and B (45%) of dissolved Moroccan subsidiary X seek deductibility of credit deterioration and income treatment upon dissolution. DGT applies same criteria: A may deduct under art. 13.1 LIS if conditions are met; B, as a linked entity, only if X is in bankruptcy with judicial liquidation. Both recognise the difference between market and fiscal value of the share received (art. 17.8 LIS), with negative income deductions reduced by prior dividends (art. 21.8 LIS).
The ruling clarifies deductibility rules for credit deterioration and income treatment in the dissolution of a non-resident subsidiary, particularly for linked entities, and sets conditions for deducting negative income, with adjustments for prior dividends.
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