Doctrine by topic · DGT Observatory

Accounting Accrual: 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 · 2016–2026

Current position

In Corporate Income Tax (IS), income and expenses are included in the tax base in the fiscal year in which their accounting accrual occurs. This criterion is applied proportionally in cases of compensation for non-compete agreements if accounting regulations so require. The temporal allocation must always respect the correlation between income and expenses according to the rules of the Commercial Code.

The DGT's position has remained constant over time, linking the allocation of income and expenses in Corporate Income Tax (IS) to the accrual established by accounting regulations. The analyzed rulings do not show changes in criterion, but rather apply this principle to different scenarios such as subsidies, leases, or compensation.

Analysis based on 7 of 8 rulings with a stated position. Updated 13 October 2026.

Rulings on this topic

8
V0199-26 30 Jan 2026

Temporary charge for rent reduction following judicial ruling

SG de Impuestos sobre las Personas Jurídicas
imputación temporalprovisión para otras responsabilidadesdevengo contablebase imponiblerebus sic stantibus LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 10.3LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 11
Affects CompanyExpat · Non-residentIndividual

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