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A company has enquired whether the impairment of a loan granted to a subsidiary is tax-deductible upon capitalisation or loss of affiliation. The DGT ruled that the capitalisation of a credit between a shareholder and a company with majority participation does not generate a tax expense, although it does increase the tax value of the holding.
Cuestión planteada Si el deterioro contable del préstamo concedido a la entidad A, es fiscalmente deducible en el período 2011 (capitalización del préstamo) o en el período 2013 (pérdida de la vinculación).
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