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The DGT confirms that no rental is included when a commercial capital increase exactly offsets debt.
Question posed: Whether the corporate operation of capital increase by compensation of credits, insofar as a capital increase has been carried out for the same amount as the existing debt, will not result in any income being included in the tax base for the taxpayer.
The capitalization of credits shall be valued in the debtor entity by the amount of the capital increase from a commercial perspective. If the entity carries out a capital increase for the same amount as the existing debt, it shall not include income in its tax base, regardless of whether an income could exist for accounting purposes. The transferring entity shall include the difference between the amount of the increase and the tax value of the credit.
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