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A holding company sought clarification on whether it must apply the financial expense deductibility limit, given that it is not individually subject to insurance solvency margins. The DGT ruled that, as part of a consolidable group of insurers, it is treated as an insurance entity and is therefore exempt from this limitation.
This ruling provides tax certainty for holding companies within insurance groups, allowing them to bypass certain interest deductibility restrictions typically applied to non-financial entities.
The tax team reviews your specific situation.
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