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A company has requested clarification on whether losses arising from the transfer of inventory between companies within the same tax group must be eliminated or if they can be treated as non-eliminable impairment. The DGT has ruled that if the loss corresponds to an impairment of value in accordance with consolidated accounting standards, it should not be eliminated.
Cuestión planteada Si, a efectos de determinar la base imponible del grupo fiscal, la remisión que realiza el artículo 62 de la Ley del Impuesto sobre Sociedades a las normas contables consolidadas contemplaría la pérdida derivada de la transmisión de existencias intragrupo como una depreciación que no debería ser eliminada.
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