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V0058-26 13 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · pérdidas por deterioro

Losses from credit deterioration of Cuban state importers may be deductible if LIS insolvency conditions are met

A Spanish company asks whether losses from credit deterioration of Cuban state importers are deductible. The DGT states that deductibility depends on meeting the LIS insolvency conditions and that the legal nature of Cuban entities cannot be determined.

The question raised

Whether Cuban companies are considered public law entities or, conversely, whether the deductibility of impairment losses on credits owed by them could be considered, as specified in Article 13.1 of the LIS.

The DGT's ruling

The deductibility of impairment losses on receivables shall depend on the occurrence of any of the circumstances set forth in letters a) to d) of Article 13.1 of the LIS, provided that none of the exclusion situations in ordinals 1 to 3 apply. The DGT does not assess the legal nature of Cuban state entities, but notes that the concept of public entities for the purpose of exclusion from deductibility refers solely to Spanish entities.

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