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V2724-17 ·24 October 2017 ·consulta-vinculante Medium impact
Tax

Forgiveness of a loan between companies has no impact on partners' Personal Income Tax, unless part of a global transaction

An individual has enquired whether the forgiveness of a loan between two companies in which they hold shares affects their Personal Income Tax (IRPF). The Directorate General for Taxes (DGT) indicates that, as a general rule, the transaction has no effect on the partners as they are not parties to the loan. However, it warns that if the forgiveness is part of a more complex global transaction, the entire operation must be analysed as a whole.

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2017-10-24PublishedPublished 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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