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V0294-26 12 February 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · dación en pago

Integration of the market value minus fiscal value difference into taxable base in a payment by asset transfer

The DGT states that the entity must integrate the difference between the market value and fiscal value of the credit into the period in which the transaction takes place.

The DGT's ruling

The entity must include in the tax base the difference between the market value of the item (credit) and its tax value in the period in which the cancellation is carried out. The acquiring entity shall value the items received at their normal market value. If there is a difference between the book value and the tax value in the acquirer, the inclusion will depend on whether the item is current assets, depreciable fixed assets, or non-depreciable fixed assets, pursuant to Article 20 of the LIS.

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