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V3009-17 20 November 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · estimación directa simplificada

Tax deductibility of credit impairment from a prescribed period is not permitted

A taxpayer operating under the simplified direct estimation method inquired whether they could apply a loss from the impairment of trade receivables in 2015 or 2016. The DGT ruled that, although accounting standards allow for the recognition of expenses from previous periods, they cannot be tax-deductible if the expense pertains to a period that has already become prescribed.

The question raised

Whether in 2015 or 2016 an impairment loss on trade receivables could be recognized for the aforementioned debit balance.

The DGT's ruling

To determine the net income under the direct estimation method, the rules of Corporate Income Tax are applied. If an impairment loss should have been recorded when the risk was identified (in this case, in 2010), its allocation in subsequent financial years is only possible if it does not result in a lower tax liability than would have corresponded under the general rules. As it concerns an expense from a statute-barred financial year, its deduction in 2015 or 2016 would imply a lower tax liability than due, therefore its tax deductibility is not applicable.

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