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A partner inquired about the tax treatment of forgiving a debt owed to her company to strengthen its equity. The DGT ruled that this contribution must be integrated into the acquisition value of the shares.
Cuestión planteada Tratamiento fiscal de dicha operación en el Impuesto sobre la Renta de las Personas Físicas.
La aportación de socios mediante la condonación de un crédito debe integrarse en el valor de adquisición de las participaciones, siempre que la parte condonada corresponda al porcentaje de participación de cada socio. Para que se considere aportación a fondos propios, debe realizarse sin derecho a devolución ni contraprestación alguna.
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