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V1531-25 26 August 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · subvenciones no reintegrables

Imputation of non-recoverable subsidies depends on purpose and accounting rules

The consultant asks whether a subsidy should be recognised in the year of notification or in the year of collection. The DGT states that imputation must follow accounting rules based on the subsidy's purpose.

The question raised

Question posed: Should the grant be recognized in the financial year of the notification of the granting agreement or, conversely, in the one corresponding to the moment of the collection of the grant?

The DGT's ruling

The recognition of income from non-repayable grants is carried out according to their purpose pursuant to NRV 18 of the General Accounting Plan. If the grant is intended to ensure profitability or to compensate for operating deficits, it is recognized in the financial year in which it is granted. For tax purposes, the treatment shall be the same as the accounting treatment, as there are no rules in the Corporate Income Tax Act that correct this criterion. The right to collection must be recognized when the granting agreement exists, regardless of when the collection is materialized.

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