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V2506-24 10 December 2024 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · subsanación error contable

Charges to reserves not included in taxable base under accounting policy changes or error corrections

The company asked whether it could reduce the value of garages and storage units against reserves in 2022 to adjust its balance sheet. Tax authorities replied that charges to reserves do not form part of the taxable base if the correction is made in accordance with the PGC.

The question raised

Question posed: Is it correct and possible to record this decrease in value of the parking spaces and storage rooms against reserves in the year 2022 in order to reflect their real value in the balance sheet and provide a more accurate view of the company's reality? Given that all sales have already been declared between the 2020-2021 financial years and some in 2022.

The DGT's ruling

If the valuation adjustment is carried out in accordance with Accounting Standard 22 of the General Accounting Plan (PGC), Article 11.3.2 of the Corporate Income Tax Act (LIS) applies. Therefore, charges or credits to reserves related to income or expenses accrued and recorded under previous criteria that were already included in the taxable base of those periods shall not be included in the taxable base. Likewise, income or expenses recorded again due to the change in accounting policy shall not be included.

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