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A company has requested a ruling on the tax treatment of discount vouchers for users and money transfers. The DGT has determined that these vouchers constitute customer acquisition expenses, which are deductible for Corporate Income Tax, and represent capital gains for the user under Personal Income Tax.
Cuestión planteada Impuesto sobre Sociedades:
En el Impuesto sobre Sociedades, los vales descuento para captar clientes son gastos deducibles por promocionar la venta de bienes, sin aplicar el límite del 1% de las atenciones a clientes. Para el perceptor, estos vales o transferencias de dinero se califican como ganancias patrimoniales en el IRPF, determinadas por su valor de mercado. En el IVA, las transferencias bancarias son operaciones sujetas pero exentas.
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