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The query asks when the reversal of impairment losses on participations should be recognised and how transfers affect it. The DGT responds that the reversal takes place on the last day of the tax period and, if a transfer occurs, the outstanding amount is integrated with the positive income limit.
Question raised 1. Regarding the reversal of impairment of securities representing participation in the capital or equity of entities referred to in paragraph 3 of the sixteenth transitional provision of Law 27/2014, the question arises as to at what point in each tax period the obligation to impute the reversal in fifths arises. Whether, in the event of the transfer of the holdings, the amount to be included in the tax base for the impairment pending reversal at the date of the transfer shall be limited to the amount of the positive income, such that no additional amounts shall have to be reversed in the future.
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