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V0133-15 16 January 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deterioro de valor

Capital reduction and increase do not generate income for shareholders

A company inquired whether a accounting write-down and its associated impairment allowed an extra-accounting adjustment to reduce taxable base. The DGT states that capital reduction and increase in the subsidiary have no fiscal impact, and the recorded impairment is a positive temporary difference.

The question raised

Question posed: Whether the accounting derecognition of both the consulting entity's investment in Y and the impairment loss associated with said investment entails an extra-accounting adjustment to the tax base for the 2013 tax period, insofar as the losses initially recorded as reversible (valuation adjustments for impairment) become irreversible losses in the 2013 financial year due to the derecognition of the investment in the accounts. Whether such an extra-accounting adjustment would result in a reduction of the 2013 tax base by an amount equivalent to the tax value of the investment in Y as of December 31, 2012. And whether the aforementioned extra-accounting adjustment should be reversed as a consequence of the occurrence of any of the following circumstances:

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