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V2020-24 23 September 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · fondo de comercio

Goodwill may be amortised over a period exceeding 20 years if its useful life justifies it

The applicant inquired whether it is possible to amortise the goodwill of a pharmacy over a period longer than 20 years. The DGT ruled that tax amortisation must follow the accounting useful life; however, when the useful life cannot be reliably estimated, the maximum annual limit is set at one twentieth of the total amount.

The question raised

Taking into account that, according to ruling V2767-11, the amortization of one twentieth of the acquisition price of the goodwill constitutes a maximum annual limit, whereby a lower amount may be deducted annually, it is inquired whether the goodwill could be amortized over a period exceeding 20 years.

The DGT's ruling

Goodwill is amortized for accounting purposes according to its useful life, which is presumed to be ten years unless proven otherwise. For tax purposes, amortization is deductible up to a maximum limit of one twentieth of its amount. If the useful life exceeds twenty years, it is not necessary to make extra-accounting adjustments for the determination of the taxable base.

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