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The consultant asks whether the termination of a purchase and sale agreement and a simultaneous capital reduction and increase operation (accordion operation) in its investee generate extra-accounting adjustments in Corporate Income Tax. The DGT determines that the accordion operation must not produce a tax impact if it does not originate an accounting entry in the shareholder.
Question posed - Whether the accounting entry of the termination of the purchase and sale agreement would motivate any extra-accounting adjustment for the purposes of determining the taxable base in Corporate Income Tax.
In the accordion operation, if the ownership percentage does not vary and there are no doubts regarding the going concern, no investment write-off or accounting loss should be recorded. As there is no impact on the accounting result pursuant to Article 10.3 of the LIS, there is no tax effect on the taxable base. Regarding the termination of the contract, the difference between the price and the fair value is treated as a distribution of reserves or recovery of investment depending on the shareholding, and the remainder as a donation.
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