The Spanish Directorate General for Taxation confirms the tax treatment of hybrid instruments issued by Spanish entities (June 2021)
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Introduction
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The Spanish Directorate General for Taxation (Dirección General de Tributos, the "DGT") recently issued a binding ruling (V0143-21), confirming the tax deductibility of the remuneration of hybrid instruments issued by Spanish entities. The key development arising from the ruling is that it uncouples the accounting treatment of an instrument from the tax deductibility of the remuneration as an expense.
