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An investor asks whether they must file Model 720 for shares in loans through a foreign participative financing platform. The DGT responds that loans are not declared if no representative securities exist, but balances in the platform account must be reported.
Question raised
The transfer of equity capital is only declared in Form 720 if it is implemented through representative securities. If the participation in loans is not represented by securities, there is no obligation to report those amounts. However, amounts held in the management entity that are not invested in loans must be declared as foreign accounts pursuant to Article 42 bis of the RGAT, subject to exemptions.
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