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V0534-20 5 March 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · amortización

Amortisation expenses are deductible when applying linear coefficients from the Corporate Tax Act tables

A company inquired whether the amortisation of real estate investments using linear coefficients from the official tables is correct and deductible. The Directorate-General for Taxes (DGT) ruled that such expenses are deductible if the maximum coefficient is applied, or any other coefficient falling between the maximum and the one derived from the maximum amortisation period.

The question raised

1. Whether, for the purposes of calculating the taxable base of Corporate Income Tax, the accounting of the depreciation expense in accordance with the application of the linear depreciation coefficients established in the tables is correct and, therefore, the depreciation expense accounted for in accordance therewith is tax deductible.

The DGT's ruling

The depreciation expense is deductible if it corresponds to effective depreciation. If the table method is used, depreciation is effective if a linear coefficient is applied that is between the established maximum and that derived from the maximum depreciation period. In the case of acquired used assets, the deductible depreciation is the amount resulting from multiplying by two the amount derived from applying the maximum linear coefficient.

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