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V0804-16 29 February 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · activos no corrientes mantenidos para la venta

Impairment of properties held for sale classified as non-current assets is tax-deductible

A query was raised regarding whether the impairment of assets acquired through debt enforcement (properties received in lieu of payment) is tax-deductible. The DGT ruled that, as these assets form part of the entity's ordinary course of business, they must be treated for tax purposes as inventory.

The question raised

Tax deductibility of the impairment loss of assets allocated as non-current assets held for sale.

The DGT's ruling

The allocated real estate properties, although accounting-wise classified as non-current assets held for sale, maintain the nature of ordinary business for the securitization entity. Therefore, they must receive the tax treatment of inventory, which allows for the deductibility of their impairment according to the LIS.

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