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A shareholder with 33% of a company's capital seeks advice on the tax treatment of a loan granted by the company. The DGT states that where there is a relationship, the transaction must be valued at market value, and the difference from the agreed amount has specific tax treatment.
Question posed: Taxation of said loan under Personal Income Tax (IRPF).
As a related-party relationship exists due to a holding exceeding 25%, the loan must be valued at its market value. If the agreed interest rate differs from the market rate, the difference shall receive the tax treatment corresponding to the nature of the resulting income, pursuant to Article 18.11 of the LIS. In the event of an adjustment, the base for withholding tax shall be the difference between the agreed value and the market value.
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