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V1190-20 30 April 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · fondo de comercio

Goodwill of a lottery administration may be amortised with a 5% annual limit

A company enquired whether the cost of acquiring a lottery administration could be amortised as intangible assets with an indefinite useful life. The DGT ruled that if goodwill is identified in the acquisition, its amortisation is tax-deductible subject to a limit of one-twentieth of its value.

The question raised

Possibility of amortizing as indefinite-lived intangible assets the transfer cost / goodwill paid for the assignment of a license for the operation of a lottery administration and, where applicable, the percentage applicable to Corporate Income Tax.

The DGT's ruling

If goodwill is identified in the acquisition of a lottery administration business, its accounting amortization is a tax-deductible expense. Pursuant to Article 12.2 of the LIS, the amortization of goodwill shall be deductible subject to a maximum annual limit of one twentieth of its amount.

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