Exceptions to the application of limiting the deductibility of financial expenses

The limitation on the deductibility of net financial expenses will not apply:

• To the credit institutions and insurance companies.

  For these purposes, those entities whose voting rights correspond, directly or indirectly, entirely to them, and whose only activity consists of the issue and placement on the market of financial instruments to strengthen the regulatory capital and financing of such entities, will be treated as credit institutions.

  The same treatment will also be received by mortgage securitization funds , regulated by Law 19/1992, of July 7, on the Regime of Real Estate Investment Companies and Funds and on Mortgage Securitization Funds, and the asset securitization funds referred to in Additional Provision fifth.2 of Law 3/1994, of April 14, which adapts Spanish legislation on credit to the Second Banking Coordination Directive and introduces other modifications relating to the financial system.

• In the tax period in which the extinction of entity occurs, unless it is a consequence of a restructuring operation.