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V5083-26 26 June 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · devengo

Revenue recognition for services depends on the transfer of control and accounting accrual, not on invoicing

The DGT clarifies that income is recognised when control of the service is transferred, according to the degree of progress, and that prior pre-recognition does not allow fiscal correction through error adjustment.

The question raised

Question posed: Accounting treatment and taxation that must be applied to income obtained, considering that invoicing is carried out prior to the provision of the service.

The DGT's ruling

Revenue recognition does not depend on invoicing or collection, but on the transfer of control of the service to the customer pursuant to NRV 14 of the PGC. If the service is provided over time, revenue is recognized according to the stage of completion or progress. If the stage of completion cannot be measured, revenue shall only be recognized to the extent of the costs incurred that are expected to be recovered. The correction of an early recognition error through adjustments in reserves does not alter the tax integration already performed in the period of its accounting.

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