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V5458-16 27 December 2016 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · prestación patrimonial

Asset conversion payments for deferred tax are deductible expenses for Corporate Income Tax

A query was raised regarding whether the payment of the equity contribution regulated in the thirteenth additional provision of the LIS is deductible. The DGT ruled that, as it is not included in the list of non-deductible expenses under Article 15 of the LIS, the expense is tax-deductible.

The question raised

Whether the indicated equity contribution is considered a deductible expense for Corporate Income Tax purposes.

The DGT's ruling

The accounting expense for the equity contribution due to the conversion of assets from deferred tax to recoverable credit is deductible in the Corporate Income Tax taxable base. This is because said contribution is not included in the list of non-deductible expenses under Article 15 of the LIS.

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