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Practical Manual of Companies 2022.

Exceptions to the application of limiting the deductibility of financial expenses

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

  • To credit institutions and insurance companies .

    For these purposes, those entities whose voting rights correspond, directly or indirectly, entirely to them, and whose sole activity consists of the issuance and placement on the market of financial instruments to reinforce regulatory capital and the financing of such entities.

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

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