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A company seeks advice on the tax treatment of a participative loan to a non-resident administrator or shareholder. The DGT clarifies that if a relationship exists, the Administration may value the transaction at market value and assess taxation based on the lender's residency.
Cuestión planteada 1) Cómo sería la tributación en sede del prestamista y del prestatario en el caso de que se tuvieran pérdidas.
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