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The consultant asks whether the reversal of a shareholding impairment, deductible individually but eliminated in consolidation, must also be removed from the group's tax base. The DGT responds that since the impairment was not a deductible expense at the group level, its reversal must also be eliminated.
Cuestión planteada Si en sede del grupo de consolidación fiscal, el importe correspondiente a la reversión del deterioro de las participaciones que se realiza en la base imponible individual (deterioro que en su día fue fiscalmente deducible, pero objeto de eliminación a nivel de la base imponible consolidada), debe ser objeto de eliminación de la base imponible del grupo, conforme tanto al texto refundido de la Ley del Impuesto sobre Sociedades como a la Ley del Impuesto sobre Sociedades.
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