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V3436-15 11 November 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deterioro de valor

Reversal of impairment losses on tangible fixed assets is included in the tax base when book value is recovered

The query asks how to tax the reversal of impairment losses on tangible fixed assets recorded in 2014. The DGT rules that inclusion in the tax base occurs during the period in which the recovery of value is recognised for accounting purposes.

The question raised

How should the possible future reversals of these impairments (2015 and onwards) be tax-allocated, whether the amount recovered in 2015 and onwards is tax-allocated in its entirety until the tax-impaired amount is recovered, or whether the amount is allocated in proportion to the part that was deductible at the time.

The DGT's ruling

Reversals of impairment losses on tangible fixed assets that were tax-deductible in periods prior to 2015 shall be included in the Corporate Income Tax taxable base in the period in which the recovery of their carrying amount occurs. This applies both to impairments from the current financial year and to those from previous financial years that have not expired. In the case of impairments from expired financial years, although they are not deductible in the year of their recording, their reversal shall also be included in the taxable base when the carrying amount is recovered.

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