How the DGT's position has evolved
Current position
Small-sized enterprises may apply goodwill amortization equivalent to 150% of the annual limit of one-twentieth of its amount (7.5% annually). For the freedom of amortization in works execution contracts, the entity must be small-sized at the time of signing the contract, provided that the availability occurs within the following 12 months. The determination of turnover for the group must consider the turnover of the previous period of the entities comprising the group on the last day of the tax period.
The DGT's position remains constant in the application of specific benefits for these entities, such as the accelerated amortization of goodwill at 150% of the legal limit. Rulings have specified the calculation of turnover in groups of companies and the temporal requirements for the freedom of amortization in works contracts. No changes in criterion are observed, but rather a repeated application of the provided tax incentives.
Turning points
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Establishes that for the turnover limit, the amount of companies where control exists according to article 42 of the Commercial Code must be computed jointly.
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Specifies that for the freedom of amortization in works execution contracts, the contract must be signed when the entity is small-sized, with a 12-month margin for availability.
Analysis based on 20 of 23 rulings with a stated position. Updated 24 September 2026.