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V2614-25 23 December 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deterioro de créditos

Conditions for the tax deductibility of credit loss provisions under the LIS

A company asks whether it can deduct as an expense losses from uncollectible credits following the death of a debtor and the liquidation of their inherited assets. The DGT responds that deductibility depends on meeting the LIS insolvency conditions and on the expense being recorded in the accounts.

The question raised

Whether it is correct, for tax purposes, the previously stated criterion of considering as deductible expenses for Corporate Income Tax purposes the losses incurred by companies B and M arising from uncollectible credits derived from loans granted or balances maintained with the deceased, to the extent that the hereditary assets failed to cover them after being liquidated under the terms set forth.

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