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V1883-24 8 August 2024 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · subvenciones

Grants for forest estates are excluded from the taxable base if the production period is 20 years or more

A company sought clarification on whether grants received under a forest estate management plan should be subject to Corporate Tax. The DGT has ruled that they will not be taxable, provided the requirement of an average production period of at least 20 years is met.

The question raised

1. Taxation of the subsidy in Corporate Income Tax, in relation to Article 19.6 of Law 27/2014, of November 27, 2014.

The DGT's ruling

Subsidies for forest estates managed under approved technical plans shall not be included in the tax base if the average production period of the species is equal to or greater than 20 years. If this requirement is not met, the subsidy must be included in the tax base when the income is recorded in the accounting result. In the event that the subsidy is not included in the tax base, the expenses financed by it shall not be tax deductible in order to avoid a loss of taxation.

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