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V0292-21 18 February 2021 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · riesgo de crédito

Deductibility of credit risk coverage governed by current law

The DGT responds that the eighth transitional provision of the RIS no longer applies and that accounting adjustments are integrated in accordance with general rules.

The question raised

1. Whether the provisions of the eighth transitional provision of the Corporate Income Tax Regulations, approved by Royal Decree 634/2015, of July 10, are no longer applicable, and whether the deductibility of credit risk coverage for financial credit institutions shall be determined in accordance with Article 9 of the Corporate Income Tax Regulations in force as of January 1, 2020.

The DGT's ruling

The entry into force of Bank of Spain Circular 4/2019 constitutes the specific regulatory development for the submission of accounting information. Therefore, the eighth transitional provision of the RIS ceases to be applicable, and the deductibility of provisions for credit risk coverage shall be determined according to the regulation in force at the time of accrual. Charges or credits for accounting adjustments derived from Circular 4/2019 shall be included in the taxable base following the general rules of the Corporate Income Tax.

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