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A company has enquired whether it can apply accelerated depreciation to moulds and tooling acquired for a technological innovation project. The Directorate General for Taxes (DGT) has ruled that this tax benefit is exclusive to research and development activities, rather than technological innovation activities.
Question raised 1. Whether it is possible to apply the freedom of depreciation regulated in Article 11.2 of the TRLIS, considering that it concerns a technological innovation project.
The freedom of depreciation provided for in Article 11.2 of the TRLIS is reserved for assets used in research and development activities. As this is a technological innovation activity, said tax benefit is not applicable. However, the depreciation of assets directly used for technological innovation may form part of the base for the corresponding deduction pursuant to Article 35.2 of the TRLIS.
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