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An entity sought clarification on whether the delivery of a vessel and the conclusion of a financial lease had occurred pursuant to Article 106 of the Corporate Income Tax Act (LIS). The Directorate General for Taxes (DGT) confirms that, based on the facts described, the vessel has been delivered and the lease has concluded.
Cuestión planteada Si a los efectos del artículo 106 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades, se ha producido la entrega del buque y ha concluido el arrendamiento financiero.
De los hechos descritos se desprende que el buque objeto del contrato de arrendamiento financiero ha sido entregado a la entidad arrendataria y que dicho arrendamiento ha concluido a los efectos del artículo 106 de la LIS.
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