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A securitisation fund manager has requested clarification on whether variable fees should be classified as financial income or financial expenses for the purpose of applying the financial expense deductibility limit. The DGT has ruled that variable fees must follow the nature of the items they offset (financial or non-financial) to prevent fiscal asymmetries.
Question posed - Confirmation of whether the Variable Commission should be considered within the framework of securitization funds as income or expense (depending on whether the result is positive or negative) of a financial nature for the purposes of the provisions of Article 16.1 of the LIS regarding the deductibility of financial expenses in the IS.
The variable commission must be taken into consideration to determine the net financial expense for the fiscal year to the extent that it corresponds to the difference between income and expenses of a financial nature. The portion of the variable commission resulting from the difference between non-financial income and expenses shall not be affected by the deductibility limitation of Article 16 of the LIS. This treatment seeks to maintain neutrality and ensure that only items related to corporate indebtedness are affected by the limit.
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