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V3529-20 ·10 December 2020 ·consulta-vinculante Medium impact
Tax

Expenses for the delivery of parent company shares to subsidiary employees are deductible in the year of delivery

A Spanish subsidiary seeks clarification on whether it can deduct expenses arising from the granting of parent company share options to its employees, given that the parent company bears the cost without compensation. The DGT rules that the expense is deductible in the tax year in which the actual delivery of the shares takes place.

In 6 key points

How it affects those involved

This ruling clarifies the timing of tax deductibility for share-based compensation involving parent companies, confirming that the deduction occurs upon the effective delivery of shares rather than at the time of granting options.

Lifecycle

2020-12-10PublishedPublished 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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