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V1203-23 ·9 May 2023 ·consulta-vinculante Medium impact
Tax

Inclusion of unavailable reserves and proportional income under the general regime in the tax base

A shipping company seeks clarification on how to calculate positive income from the sale of a vessel after having taxed under both the tonnage regime and the general regime. The DGT rules that the unavailable reserve and the portion of income corresponding to the period taxed under the general regime must be included in the tax base.

In 6 key points

How it affects those involved

This ruling clarifies the tax treatment for shipping companies transitioning between tax regimes, ensuring that the disposal of assets accounts for both the unavailable reserve and the income earned during the general tax period.

Lifecycle

2023-05-09PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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