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V2352-23 ·30 August 2023 ·consulta-vinculante Medium impact
Tax

Inventory impairment losses in intra-group transactions may not be eliminated for tax consolidation purposes

A company has requested clarification on whether losses arising from the transfer of inventory between companies within the same tax group must be eliminated or if they can be treated as non-eliminable impairment. The DGT has ruled that if the loss corresponds to an impairment of value in accordance with consolidated accounting standards, it should not be eliminated.

In 6 key points

How it affects those involved

This ruling provides legal certainty for tax groups regarding the treatment of inventory impairment, allowing certain losses to remain in the tax base if they meet accounting standards, rather than being mandatorily eliminated as intra-group profits.

Lifecycle

2023-08-30PublishedPublished 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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