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The tax consequences of forgiving a participative loan between linked companies are examined. The DGT states that if the companies are part of a coordination group, the transaction must reflect its economic reality as a distribution of funds from the lender to the borrower and a capital contribution to the borrower.
Cuestión planteada - Efectos fiscales de la condonación del préstamo participativo en el Impuesto sobre Sociedades entre sociedades dependientes.
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