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A query was raised regarding whether the value of real estate received through the early reversion of a surface right should be recognised as income in the year the reversion occurs. The DGT indicates that if the difference between the amount paid and the income already distributed generates income, this must be recognised in the period in which it accrues.
Question raised 1) Whether the value of the real estate received through early reversion must be imputed accounting-wise as income for the financial year in which the reversion occurs.
The tax imputation of income and expenses must be carried out in the period in which they accrue, respecting the correlation with the actual flow of goods and services. If the termination of the contract generates income for the entity, this must be imputed to the taxable base in the tax period corresponding to its accrual. To determine the treatment, the accounting reflection of the operation must be considered, canceling the income to be distributed over several financial years and analyzing whether the difference constitutes an increase in the value of the asset or income.
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