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V0188-25 14 February 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · base imponible

The withdrawal of cash from a bank account does not constitute a deductible expense for Corporate Income Tax purposes

A company inquires whether funds withdrawn from its bank account to mitigate pandemic risks may be considered a lost and deductible amount. The DGT responds that it is not deductible because the transaction does not represent an accounting expense nor a decrease in net equity.

The question raised

Question posed: Whether, for Corporate Income Tax purposes, said amount may be considered lost, given that it cannot be used in the company's activities.

The DGT's ruling

The withdrawal of cash from an entity's account does not constitute a tax-deductible expense for Corporate Income Tax purposes. Pursuant to Articles 10.3 and 11 of the LIS, the taxable base is calculated starting from the accounting result. As there is no decrease in net equity nor is an expense recorded, no deduction is permissible.

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