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V4138-15 28 December 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · activos por impuesto diferido

Deferred tax assets generated before 2008 are not subject to the wealth contribution tax

An association has requested clarification regarding the tax treatment of deferred tax assets and the wealth contribution tax following the reform of the Corporate Income Tax Act. The DGT clarifies when the contribution must be paid, how to calculate it, and the order of integration into the taxable base.

The question raised

Described in the body of the response.

The DGT's ruling

Deferred tax assets generated before 2008 are not subject to the wealth contribution, although they are entitled to conversion into credit. The contribution is calculated by applying 1.5% to the difference between the net generation of assets (2008-2015) and the positive net tax liabilities of that period. The integration into the tax base must follow a specific order: first, assets without the right to conversion; second, those subject to the wealth contribution; third, assets prior to 2008 or not subject to the wealth contribution; and finally, those generated from 2016 onwards.

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