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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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El deterioro de créditos con entidad vinculada (>= 25%) no es deducible en IS salvo concurso con liquidación judicial (art. 13.1.2º LIS). La baja definitiva del crédito en ejercicio posterior al devengo requiere revertir el ajuste extracontable positivo e integrar la pérdida definitiva (art. 20 LIS), sin derivar tributación inferior al devengo (art. 11.3.1º LIS). La extinción activa el art. 17.8 LIS para integrar la renta de la participación anulada, y el art. 21.8 LIS determina la deducibilidad de rentas negativas minoradas por dividendos recibidos en los diez años anteriores.
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