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V5109-16 ·25 November 2016 ·consulta-vinculante Medium impact
Tax

Forgiveness of a loan between dependent companies does not generate expense or income for Corporate Tax (except for excess participation)

The tax effect of forgiving a loan between two companies (A and B) owned by the same individual is examined. The DGT determines that, depending on the accounting treatment, no expense or income is generated for Corporate Tax purposes for the companies involved, in proportion to their shareholding.

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2016-11-25PublishedPublished 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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