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V5474-26 13 August 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducibilidad

Deductibility of expenses depends on documentary evidence and the reality of operations

A commercial agency company has requested guidance on how to justify and document its expenses. The DGT states that deductibility is subject to regulations and that justification is a matter of fact that must be proven using legally admissible means.

The question raised

Question raised It is asked:

The DGT's ruling

The documentary justification of expenses is a matter of fact that must be proven by any means admitted in Law, in accordance with the General Tax Law. Business expenses must be justified primarily through an invoice or a substitute document, although an invoice is not a privileged means of proof if the Administration questions the reality of the transaction. It is the responsibility of the taxpayer to provide evidence regarding the existence of the transactions, and the assessment of the documentation is the competence of the Administration.

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