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A company has requested a ruling on whether it can deduct a €530,000 credit impairment loss following the guaranteeing of debts, alongside a €483,900 provision for liabilities. The DGT examines the related-party status with the debtors and the specific conditions required for the deductibility of such provisions.
Question raised 1. Whether the provisioned impairment loss on receivables of €530,000 is deductible for Corporate Income Tax purposes.
Regarding the impairment loss on receivables, deductibility depends on whether the debtor is a related party or whether the insolvency scenarios under Article 13.1 of the LIS are met. In the case of SA, a related-party relationship exists, and it would only be deductible if the debtor is in insolvency proceedings with a liquidation phase. For SB, as there is no related-party relationship, deductibility depends on meeting the insolvency circumstances provided for by law. Regarding the provision for liabilities, it shall be deductible provided it meets the requirements for accounting recognition, accrual, and substantiation, and is not an expense specifically non-deductible under Article 14 of the LIS.
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