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V0078-26 20 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deterioro de créditos

Deductibility of credit impairment losses requires prior accounting recognition and compliance with art. 13.1 LIS

The consultant asks whether tax deduction is possible for a credit impairment from a liquidation entity that was not accounted for. The DGT responds that for a deduction to be allowed, the impairment must have been accounted for and meet the insolvency conditions set out in the law.

The question raised

1. Whether the portion of the credit that has not yet been impaired, because the company believed there were expectations of collection and because entity Y is in liquidation proceedings, can be provided for at the current time as a tax-deductible impairment for Corporate Income Tax purposes.

The DGT's ruling

The deductibility of impairment losses on receivables depends on the fulfillment of any of the insolvency circumstances set forth in Article 13.1 of the LIS and on the requirement that the expense has been previously recorded in the accounts. If the entity has not recognized the loss in the accounts during the period in which it was due according to the accrual principle, it shall not be able to deduct said expense for tax purposes. The taxable base is the accounting result adjusted by tax adjustments.

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