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A company has requested a ruling on the tax treatment of fair value changes in SWAPs under hedge accounting and their impact on the deductibility limit for financial expenses. The DGT clarifies that variations in equity do not have immediate tax effects and determines when they must be included for the purposes of Article 16 of the Corporate Income Tax Act.
This ruling provides legal certainty regarding the timing of tax effects for hedging instruments, ensuring that unrealised fair value changes recorded in equity do not prematurely affect the taxable base or the financial expense deduction limits.
The tax team reviews your specific situation.
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