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V0028-24 13 February 2024 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IRPF · rendimiento de la actividad económica

Grants to offset discounts on tourism services are recognised based on their purpose and accounting accrual

A query was raised regarding the taxation and timing of recognition for Castilla-La Mancha grants intended to compensate for reduced income in tourism services. The DGT ruled that their treatment depends on whether the recipient is a natural or legal person and their specific purpose.

The question raised

Question posed: To determine the classification of these subsidies for the purposes of how they should be taxed in Personal Income Tax or, where applicable, in Corporate Income Tax and, above all, their temporal recognition, since although they are aids that were granted and received in 2021, the vouchers could have been consumed in that same fiscal year and in the following two.

The DGT's ruling

For natural persons, the subsidy constitutes income from economic activity and its temporal recognition follows accounting regulations. For legal entities, they are included in the taxable base of Corporate Income Tax in the fiscal year of their accounting accrual. When compensating for the reduction in income, they are recognized as income in the fiscal year in which they are granted, unless they are intended to finance operating deficits of future fiscal years, in which case they are recognized in said fiscal years. If part of the aid must be returned because it is not applied to its purpose, it is not necessary to regularize the income since said part would not have been recognized in the results.

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