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A company inquired whether it could deduct expenses from previous years recorded via a reserve adjustment due to an accounting error. The DGT ruled that if the expense pertains to a financial year that has already lapsed, it is not deductible, in order to prevent a lower tax liability than what would have been due.
Cuestión planteada
Un gasto contabilizado en un periodo posterior al de su devengo solo será deducible si no deriva en una tributación inferior a la que habría correspondido por las normas generales de imputación. Si el gasto se devengó en un ejercicio ya prescrito por la Administración, no procede su deducibilidad fiscal tras su registro contable. En cambio, si el ejercicio no está prescrito, el gasto se integrará en el ejercicio en que se registre el cargo a reservas.
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