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V3212-17 ·14 December 2017 ·consulta-vinculante Medium impact
Tax

Tax treatment of subordinated bond conversion and issuance of new bonds in bank resolution processes

A taxpayer has requested clarification regarding the tax treatment of converting subordinated bonds into shares (which are immediately transferred without consideration) and the subsequent receipt of new bonds. The DGT has determined that the operation constitutes an amortisation of bonds and that the delivery of new bonds is treated as income in kind.

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2017-12-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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