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V0199-26 30 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · imputación temporal

Temporary charge for rent reduction following judicial ruling

A company asks in which exercise the 2020 and 2021 rent reductions should be charged following a final judgment in 2024. Hacienda responds that the expense is deductible in the accounting period of its incurrence or, if no prior provision was made, in the year when the liability from the judgment is recognised.

The question raised

In which tax year should the temporal imputation of the reduction in income be carried out pursuant to the final judicial ruling dated March 12, 2024: in the tax year in which the ruling becomes final, i.e., 2024, or in the years 2020 and 2021 to which the reduced income/revenue in question corresponds?

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