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V4139-15 ·28 December 2015 ·consulta-vinculante Medium impact
Tax

Bond-to-share conversion via credit compensation capitalisation may be exempt from IRNR under specific conditions

The DGT determines that debt restructuring involving bond exchange for loans followed by capitalisation of those loans into shares constitutes a single conversion operation, and that non-resident profits could be exempt if conditions in Law 13/1985 are met.

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2015-12-28PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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