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A property management company has enquired whether it can apply the reinvestment of extraordinary profits scheme following the sale of its client portfolio. The Directorate General for Taxes (DGT) has ruled that this regime has been repealed and only applies to income generated in periods starting before 2002.
Question posed: Whether, for Corporate Income Tax purposes, the taxpayer may avail themselves of the provisions of Article 21 of Law 43/1995 regarding the reinvestment of extraordinary profits.
Article 21 of Law 43/1995 was repealed with effect for tax periods beginning on or after January 1, 2002. The transitional regime of the Corporate Income Tax Law only allows the application of said article to income generated in periods prior to that date. Therefore, the income from the transfer in 2023 must be included in the tax base of the period in which it accrues.
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