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V2133-19 13 August 2019 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · estimación directa

Losses from the sale of a credit are tax-deductible for Corporation Tax purposes

A company sought clarification on whether the loss arising from the difference between the sale price and the carrying amount of a transferred credit was deductible. The DGT ruled that, as there are no specific provisions in the Corporate Tax Act (LIS), the accounting expense is deductible without requiring adjustments.

The question raised

Whether the loss resulting from the difference between the consideration received and the book value of the transferred credit, imputed to the results of the 2016 financial year, is tax deductible for Corporate Income Tax purposes.

The DGT's ruling

In accordance with the direct estimation method, no tax adjustments are appropriate regarding the accounting entries for the sale of a credit. Therefore, if the sale gives rise to an accounting expense, it shall be tax deductible. This loss must not be included in the calculation of net financial expense for the purposes of the limitation set forth in Article 16 of the Corporate Income Tax Act.

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