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V1560-23 6 June 2023 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · convenio de colaboración empresarial

Enterprise collaboration agreements: expenditure recognised on commitment

A company asks whether it must record the full amount of a multi-year financial aid upon signing a collaboration agreement with a foundation. The DGT responds that the expenditure is recognised accountably at the time of commitment, but its tax deductibility occurs as the agreed amounts are paid.

The question raised

Question posed: Confirmation of whether, at the level of the consulting entity, the total amount of the monetary economic aid would be considered an expense accrued accounting-wise at the initial moment of the signing of the agreement.

The DGT's ruling

The expense for the commitment to provide aid must be recorded in the fiscal year in which the agreement is signed. However, for tax purposes, the amounts paid under business collaboration agreements are deductible for Corporate Income Tax. Therefore, the initially recorded expense will be non-deductible for tax purposes, and the positive extra-accounting adjustment must be reversed as the agreed amounts are paid.

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