How the DGT's position has evolved
Current position
Goodwill is calculated as the difference between the sale price and the market value of the identifiable assets. Its amortization is deductible with an annual limit of one twentieth of its amount, although it may be increased to 150% if the conditions for small-sized enterprises are met. In Personal Income Tax (IRPF), its transfer generates capital gains or losses.
The DGT's position remains stable regarding the definition and calculation of goodwill. Rulings have provided clarifications on the expanded deductibility for small-sized enterprises and its treatment in the transfer of ownership between spouses.
Turning points
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Specifies that the amortization of goodwill may be deducted at 150% of one twentieth if the conditions for small-sized enterprises are met.
Analysis based on 47 of 49 rulings with a stated position. Updated 19 September 2026.