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V1189-20 30 April 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · ajuste extracontable

Corporate Income Tax: Out-of-period extra-accounting adjustments for previous years are not permitted

A company made an error in 2008 by failing to make an extra-accounting adjustment to its Corporate Income Tax taxable base. The query asks whether this adjustment could be made in the 2016 financial year to correct the error.

The question raised

To the extent that the Corporate Income Tax expense was imputed to the company's profit and loss account for the 2008 financial year and therefore recognized in the company's equity, whether it would be possible to make an adjustment to the accounting result of the 2016 financial year, to be presented in July 2017, for the amount of the Corporate Income Tax for the 2008 financial year.

The DGT's ruling

The extra-accounting adjustment for Corporate Income Tax must be made in the same tax period in which its accounting entry takes place. The temporal imputation of income and expenses under Article 11 of the LIS is not applicable to this case. To correct the error, the rules for the rectification of self-assessments under the General Tax Law must be applied. If the right to rectify the 2008 self-assessment has expired, it is not possible to make the adjustment in a subsequent financial year.

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