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A partner inquired whether professional services provided free of charge to her company between 2006 and 2009 could be treated for tax purposes as partner contributions to increase the value of her shareholding. The DGT indicates that, although adjusting to market value would constitute such contributions, this treatment cannot be applied if the relevant tax years have already prescribed.
Cuestión planteada Si la parte de las reservas acumuladas de la sociedad hasta el 31 de diciembre de 2009, en el importe que según manifiesta la consultante correspondería a los servicios profesionales prestados gratuitamente por la socia a la sociedad, podrían considerarse a efectos fiscales como aportaciones de socios y no como reservas procedentes de beneficios.
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