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V2139-14 4 August 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · base imponible

Discounts received from terminal sales must be recognised as income in accounting and tax results

A company acting as a mobile telephony agent and franchisee has requested guidance on how to treat variable discounts received from the operator. The DGT has ruled that these discounts must be integrated as income within the results of the business activity.

The question raised

The question is raised as to how the discount would affect the determination of the corporate income tax base.

The DGT's ruling

The tax result shall coincide with the accounting result of the mobile phone sales activity. Within said result, the discount corresponding to the distributor must be considered as income. This is based on the direct estimation method and the accrual principle of the Corporate Income Tax Law.

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