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V2299-21 16 August 2021 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · devengo

Income from the sale of goods or services is attributed to the period in which its accounting accrual occurs

A company inquired as to which tax period the sales of machinery and repair services should be attributed if invoices had been issued without the goods having been delivered or the amount having been collected. The DGT responds that tax attribution must follow the accrual criterion established in accounting regulations.

The question raised

What is the tax period in which operations accrue for Corporate Tax purposes, given that invoices were issued without the delivery of materials or the provision of services, nor the collection of the same, until March and April 2018.

The DGT's ruling

In accordance with Articles 10.3 and 11.1 of the LIS, income must be attributed to the tax period in which its accrual occurs according to accounting regulations, regardless of its collection. For the sale of goods, income is recognized when significant risks and rewards are transferred and the conditions of NRV 14 of the PGC are met. In the provision of services, income is attributed when the result can be reliably estimated, and may be period-allocated according to the stage of completion.

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