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An art trading company asks whether it can set up a deductible provision for the loss in value of an artwork. The DGT responds that the difference between acquisition cost and net realisable value is deductible if recorded in the accounts as an irreversible loss.
Question posed: Can the consulting company, in view of the loss of assets, create a tax-deductible provision, thereby creating a negative tax base that can be offset against future profits? What documentation would be necessary to justify this tax-deductible provision?
The difference between the net realizable value and the acquisition cost of inventories must be recorded in the accounts as an irreversible loss. This loss is considered tax-deductible for Corporate Income Tax purposes provided that it meets the requirements of accounting recognition, accrual, documentary justification, and is not a non-deductible expense. The irreversibility of the loss is a matter of fact that the company must prove by any means admitted by law.
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