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V1809-22 29 July 2022 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · base imponible

Service expenses are deductible if accrual, accounting, and documentation requirements are met

A query was made regarding the deductibility of expenses for the provision of services. The DGT ruled that the expense is deductible provided it is attributed to the period in which it was accounting-accrued and its documentary justification is proven.

The DGT's ruling

The tax base is calculated by adjusting the accounting result through tax adjustments. Income and expenses must be attributed to the period in which they accrue, respecting the principle of accounting correlation. Every accounting expense is deductible if it complies with accounting recognition, accrual, and documentary justification, provided it is not a specifically non-deductible expense. The substantiation of documentary justification is a question of fact that must be proven by the taxpayer.

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