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A taxpayer asks when the aid for the subsidization of a loan must be declared after being granted retroactively. The DGT responds that it constitutes a capital gain and determines its temporal imputation.
Question posed: Temporal imputation of the aid corresponding to the subsidization of the agreed loan.
The obtaining of the aid constitutes a capital gain by altering the composition of the taxpayer's assets. These gains are imputed to the tax period in which the alteration takes place, which occurs periodically according to the subsidized installments. If the aid is retroactive, the portion corresponding to past installments is imputed to the period in which the granting is communicated, unless the exigibility of the payment is later, in which case it shall be imputed when it becomes due.
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