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A company sought clarification on whether financial expenses arising from debt subject to write-offs and deferrals in a 2009 insolvency proceeding were subject to Corporate Tax regulations. The DGT clarified that while the temporal imputation criteria for income from write-offs do not apply to agreements from that date, financial expenses are indeed subject to the general limitation based on operating profit.
Cuestión planteada Si los gastos financieros reconocidos en cada ejercicio, y que tienen como origen un ingreso financiero declarado y por el que se tributó en 2009, consecuencia de la aprobación de la espera concursal, están limitados en la normativa del Impuesto sobre Sociedades.
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