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Same as V2519-24: partners A (22.5%) and B (45%) of dissolved Moroccan subsidiary X seek deductibility of credit deterioration and income treatment upon dissolution. DGT applies same criteria: A may deduct under art. 13.1 LIS if conditions are met; B, as a linked entity, only if X is in bankruptcy with judicial liquidation. Both recognise the difference between market and fiscal value of the share received (art. 17.8 LIS), with negative income deductions reduced by prior dividends (art. 21.8 LIS).
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Los gastos por deterioro de créditos son deducibles si se cumplen los requisitos del art. 13.1 LIS; para la entidad vinculada (B), solo si la filial está en concurso. En la extinción, las sociedades deben integrar la diferencia entre el valor de mercado de lo recibido y el valor fiscal de la participación (art. 17.8 LIS). Las rentas negativas por extinción son deducibles según el art. 21.8 LIS, minoradas por dividendos recibidos en los diez años anteriores, siempre que no se derive una tributación inferior.
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