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V3272-14 ·4 December 2014 ·consulta-vinculante Medium impact
Tax

Debt forgiveness from a parent company to a second-tier subsidiary results in an increase in equity

A company sought clarification on the tax treatment of the partial forgiveness of a loan granted by a branch of its German parent company, and whether its economic activity would prevent restrictions on the offsetting of tax loss carryforwards. The DGT indicates that the debt forgiveness represents an increase in equity and that the company's activity appears to avoid restrictions due to inactivity.

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2014-12-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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