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V0264-26 9 February 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · imputación temporal

Advertising campaign revenues imputed based on accounting progress in Corporate Tax

A radio broadcasting company asks how to account for advertising campaign revenues spanning fiscal years. The DGT responds that such revenues should be imputed according to the accounting principle of accrual based on the progress of the service.

The DGT's ruling

In Corporate Income Tax, service income must be included in the taxable base when it accrues according to accounting regulations, regardless of payment. If the obligation is fulfilled over time, the allocation shall be made based on the degree of progress towards the fulfillment of contractual obligations, provided that reliable information is available. For VAT, accrual occurs when the services are rendered, unless advance payments exist, in which case the tax accrues at the time of payment.

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