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V2805-18 25 October 2018 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · revalorización contable

Voluntary accounting revaluations of holdings do not generate income or increased tax value

A company has requested a ruling on the tax implications of increasing the book value of holdings received through a non-monetary contribution. The DGT has ruled that voluntary revaluations do not have any effects on Corporate Income Tax.

The question raised

What would be the tax implications for P under Corporate Income Tax regarding an increase in the book value of the holdings held by it in the entities received through the non-monetary contribution described.

The DGT's ruling

Accounting revaluations of assets are not included in the tax base if they are not carried out due to a legal or regulatory obligation. This increase in value does not determine a higher value for tax purposes of the revalued assets. Therefore, the derived income and expenses shall be determined based on the value prior to the revaluation, requiring adjustments to the accounting result.

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