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V1419-15 6 May 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducibilidad

Deductibility of PayPal expenses depends on documentary justification and accounting rules

A company asked whether payments made via PayPal can be considered deductible expenses for Corporate Tax. The DGT responds that deductibility depends on meeting accounting recording, accrual, correlation with income, and documentary justification requirements.

The question raised

1. Given that the taxpayer wishes to include as a deductible expense in Corporate Tax the payment made by the natural person, the question arises as to whether PayPal is a means of payment that meets the justification requirement necessary to be considered a deductible expense.

The DGT's ruling

Expenses are deductible provided they comply with accounting registration, the accrual principle, correlation with income, and documentary justification. For payments made via PayPal, the determination of sufficient means of proof and their assessment shall be carried out in accordance with the rules of the Civil Code and the Law of Civil Procedure, having regard to the provisions of Article 106 of the General Tax Law. Expenses must be justified, as a priority, by means of an invoice or a substitute document that meets the legal requirements.

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