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A taxpayer inquired whether the cessation of their real estate development activity was effective after deregistration, while maintaining inventory for sale in the following year. The DGT responds that if there is no actual cessation but rather a temporary suspension, the properties remain inventory assets tied to the economic activity.
Question posed: Tax significance of said situation in Personal Income Tax.
The temporary suspension of real estate development activity does not imply its cessation, therefore the properties maintain their status as tied inventory assets. For cessation to exist, it must be proven that the activity has truly ended and is not a temporary pause. If an actual cessation occurs, the properties cease to be tied assets and their market value is computed as income from the economic activity. The mere filing of the cessation declaration does not produce the cessation itself.
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