Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The forgiveness of debts between dependent companies, held by the same shareholders in identical percentages, is treated as a distribution of profits for the donor and a contribution of equity for the recipient. In Corporate Income Tax (IS), this operation does not generate a deductible expense for the donor nor taxable income for the debtor. In Personal Income Tax (IRPF), these operations do not produce effects on the tax base of the shareholders as they are unrelated to the loan or the contribution.
The DGT's position has remained constant since 2014 regarding the treatment of debt forgiveness between companies with the same shareholder composition. The criterion establishes that the portion coinciding with the shareholding is considered a distribution and a contribution of equity, without generating effects in the IS or in the IRPF of the shareholders. No changes are observed in the doctrine applied to this scenario.
Analysis based on 17 of 19 rulings with a stated position. Updated 25 September 2026.