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V3527-15 ·17 November 2015 ·consulta-vinculante Medium impact
Tax

Dividends returning capital contributions to offset losses reduce the tax value of the holding

A company requested clarification on whether dividends received after making a contribution to offset a subsidiary's losses are considered a return of capital. The DGT ruled that these dividends reduce the tax value of the holding and are not included in the taxable base, but the associated impairment is not deductible.

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2015-11-17PublishedPublished 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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