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An extractive company has enquired whether it can account for a rural plot at its appraised value as fixed assets, while recording the premium paid for extractable resources as raw materials. The Directorate General for Taxes (DGT) has ruled that the tax treatment shall follow the accounting treatment applied, in accordance with the ICAC report.
Question raised: Whether it would be correct to account for and record the purchase and sale of the aforementioned plot, part of it as tangible fixed assets used for business purposes according to the appraisal value performed, and to record the remainder, i.e., the premium over the appraisal, as inventory for the amount corresponding to the resources that will be subject to extraction. This question is raised following the provisions of Article 10.3 of the Corporate Income Tax Law for the purpose of determining its taxable base.
The initial valuation of the acquired plots for tax purposes shall be that resulting from the application of accounting regulations, pursuant to the provisions of Article 10.3 of the LIS. Likewise, the depreciation of the portion of the plots corresponding to the resources shall be governed by the accounting treatment resulting from the applicable regulations, in accordance with Articles 10.3 and 12 of the LIS.
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