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V2334-15 24 July 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducibilidad

Remuneration for services other than the role of director is deductible for Corporate Income Tax purposes under certain conditions

A query is made as to whether the company may deduct as an expense the remuneration paid to its directors for performing IT work. The DGT responds that such amounts are deductible provided that the requirements of accounting registration, accrual, correlation, and substantiation are met, as these are functions distinct from those of a director.

The question raised

Question posed 1) Whether the remuneration received by the directors for their work as IT specialists in the company would be a tax deductible expense for the company.

The DGT's ruling

Expenses for remuneration of partners for services other than director functions are tax deductible for Corporate Income Tax purposes. To this end, they must comply with the conditions of accounting registration, accrual-based imputation, correlation of income and expenses, and documentary substantiation. Said expenses constitute the consideration for functions distinct from those of a director.

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