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A consultancy firm has enquired whether the remuneration paid to its three managing partners is deductible for Corporate Tax purposes. The Directorate General for Taxes (DGT) has ruled that it is deductible, provided that the conditions regarding accounting registration, accrual, correlation between income and expenses, and documentary justification are satisfied.
Question raised 1) Whether the remuneration received by the partners can be considered a deductible expense in Corporate Income Tax.
Expenses for remuneration of partners for work performed are tax-deductible provided they are not considered gifts. To this end, they must comply with the conditions of accounting registration, accrual-based imputation, correlation of income and expenses, and documentary justification. Furthermore, transactions between related parties must be valued at their normal market value.
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