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The taxpayer asks whether the capitalisation of receivables through a capital increase involving a share premium continues to generate no taxable income. The DGT rules that no income will be included in the tax base if the transaction is carried out for the same amount as the debt, in accordance with commercial regulations.
Question raised 1. Whether, taking into account the new steps described regarding the capitalization of receivables, the criterion expressed in the response to the previous inquiry would still apply to the taxpayer upon receipt of the credit and capital increase with a share premium for the same amount as the existing debt, under the terms established in commercial regulations.
Capital increase operations through the offsetting of receivables are valued for tax purposes at the amount of the commercial increase. If a capital increase with a share premium is carried out for the same amount as the existing debt, no income shall be included in the tax base, regardless of whether an accounting gain exists. For demergers and exchanges of securities, the special regime may be applied if they constitute an autonomous economic unit and their primary objective is not tax fraud or evasion.
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