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Insolvency Agreement: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2015–2026

Current position

The loss of assets resulting from a debt write-off is computed in the period in which the approval of the agreement becomes final, being integrated into the general tax base. In the case of shares received, the loss of assets is only computed after the dissolution and liquidation of the company, comparing the value of the assets received with the acquisition value of the shares.

The DGT has addressed various aspects of the insolvency agreement, from integration into tax groups to the imputation of income from debt write-offs. Recently, the doctrine has focused on specifying the timing for computing asset losses from write-offs and the valuation of shares received following liquidation.

Turning points

  1. V2281-15

    Establishes that income from write-offs and deferrals is imputed as financial expenses derived from the debt are recorded.

  2. V1552-22

    Determines the application of the taxpayer's investment in real estate transfers within the insolvency process, including the agreement phase.

  3. V0563-26

    Specifies that the loss from a write-off is computed upon the finality of the agreement and that the loss from shares received requires the dissolution and liquidation of the company.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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