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A shareholder with a 50% stake in a company inquires about the tax treatment of the forgiveness of a loan granted by the company. The DGT determines that the transaction must be valued at market value and analyzes the impact on Corporate Income Tax and Personal Income Tax.
Question posed: What tax treatment should be applied to the proposed scenario for both the company and the shareholder.
In Corporate Income Tax, the forgiveness of loans between related entities must be valued at market value pursuant to Article 17 of the LIS. For the donor company, the excess over the shareholder's effective stake is considered a non-deductible expense as it constitutes a gratuity. In Personal Income Tax, if the forgiveness is not consideration for a service, it is classified as income from movable capital.
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