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A query was raised regarding the tax value of participating loans upon capitalisation and its subsequent consequences. The DGT ruled that an entity performing a capital increase through the offsetting of credits does not include such amounts as income in its tax base.
Question raised 1) The question is raised as to what the tax value of the participating loans to be capitalized would be and the tax consequences.
In capital increase operations through the set-off of credits, the transferring entity incorporates the difference between the amount of the increase and the tax value of the capitalized credit. If the entity receiving the credit carries out a capital increase for the same amount as the existing debt, it shall not incorporate income into its tax base, provided that such debt has not been acquired from third parties.
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