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A company has requested a ruling regarding the deductibility of expenses for services provided by its sole director. The DGT has ruled that these expenses are deductible provided they do not constitute remuneration for their role as director, align with market value, and comply with accounting and substantiation requirements.
Cuestión planteada Para que las facturas sean deducibles en el Impuesto sobre Sociedades:
El gasto por servicios de un administrador es deducible si cumple con la inscripción contable, el devengo, la correlación de ingresos y gastos y la justificación documental. Además, debe valorarse a valor de mercado según el artículo 18 de la LIS y no debe ser un gasto no deducible por aplicación de preceptos específicos, como los donativos o liberalidades. La justificación documental es una cuestión de hecho que debe acreditarse por medios admitidos en Derecho.
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