The Spanish Directorate of Taxes issued a Resolution on 16 July 2012 (Official Gazette of 17 July 2012), with the purpose of clarifying the manner to calculate the net expense deduction limitation introduced by Royal-Decree Law 112/2012, of 30 March 2012, as amended by Royal-Decree Law 20/2012, of 13 July 2012 (see Spain-1, News 23 July 2012).
This limitation allows companies to deduct their net financial expenses only up to 30% of their operating profit (EBITDA), with a minimum d…