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Practical Handbook for Companies 2021

Financial expenditure arising from debts with entities in the group

In accordance with the provisions of article 15 h) of the LIS, financial expenses accrued in the tax period arising from debts with group entities in accordance with the criteria established in article 42 of the Commercial Code, regardless of residence and the obligation to prepare consolidated annual accounts, for the acquisition from other group entities of shares in the capital or equity of any type of entity, or for contributions to the capital or equity of other group entities, are not deductible, unless the taxpayer can prove that there are valid economic reasons for carrying out such operations, such as restructuring within the group, a direct consequence of an acquisition from third parties, or cases in which there is genuine management of the acquired investee entities, or in which the taxpayer has a direct interest in the group's capital or equity, or in which there is a real management of the investee entities.

Filling in form 200

For these purposes, in the tax period in which the aforementioned financial expenses considered non-deductible for tax purposes are accounted for, a positive adjustment must be made to the accounting result in box [00508] "Financial expenses derived from debts with group entities (art. 15 h) LIS)" on page 12 of form 200.