How the DGT's position has evolved
Current position
To apply the deduction under Article 106.8 of the LIS (Corporate Income Tax Law), the contract must comply with the requirements of paragraphs 1 to 4. The deduction of the portion of the quotas for cost recovery may be anticipated to the effective start of construction if the assets are tangible fixed assets, the construction lasts at least 12 months, and the asset possesses unique technical and design requirements.
The sequence of rulings does not show a doctrinal evolution on a single concept, but rather addresses various matters regarding deductions and deductible expenses in an unconnected manner. There is no identifiable evolutionary trajectory in the provided corpus.
Analysis based on 8 of 8 rulings with a stated position. Updated 19 October 2026.