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V5469-16 ·28 December 2016 ·consulta-vinculante Medium impact
Tax

Fiscal treatment of debt forgiveness between a parent and 100% owned subsidiary

The DGT states that debt forgiveness by a parent to a 100% owned subsidiary is treated as a contribution to own funds, not as income for the parent.

In 6 key points

How it affects those involved

Debt forgiveness within a 100% owned group is not considered taxable income but rather a contribution to own funds.

Lifecycle

2016-12-28PublishedPublished 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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