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V3529-20 10 December 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · pagos basados en instrumentos de patrimonio

Expenses for the delivery of parent company shares to subsidiary employees are deductible in the year of delivery

A Spanish subsidiary seeks clarification on whether it can deduct expenses arising from the granting of parent company share options to its employees, given that the parent company bears the cost without compensation. The DGT rules that the expense is deductible in the tax year in which the actual delivery of the shares takes place.

The question raised

Is the delivery by the parent company to the applicant's employees of shares in the parent company at a price below their market value deductible in the calculation of the applicant's Corporate Income Tax taxable base? In which fiscal year would such an expense be deductible?

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