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A financing entity inquired whether promissory notes issued by debtor companies under a 'Framework Program' to repay loans should be taxed under Documented Legal Acts. The DGT clarifies that, although the issuance falls within the scope of commercial documents, there is a specific exemption for loans and their instruments.
Question posed: Whether the promissory notes issued by corporate debtors (companies) under the aforementioned 'Framework Program', as a means of instrumenting the financing granted by the inquirer in the exercise of its habitual financing activity, must be subject to taxation under the modality of Documented Legal Acts, Commercial Documents, of the Tax on Transfers and Documented Legal Acts.
The issuance of promissory notes issued at a discount, in nominative but transferable form, to repay a loan, is subject to the modality of documented legal acts (commercial documents) pursuant to Article 33 of the TRLITPAJD. Nevertheless, said promissory notes are exempt from the tax in accordance with Article 45.I.B).15 of the same text, which exempts loans regardless of their form of instrumentation.
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