How the DGT's position has evolved
Current position
Financial expenses are deductible if they meet the requirements of accounting entry, accrual, and substantiation, and do not constitute donations or gratuities. This deductibility is subject to the limitation of article 16 of the Law on Corporate Income Tax (LIS), which establishes a limit of 30 percent of the operating profit for the fiscal year with a minimum of 1 million euros. Likewise, the results of joint account contracts are fiscally assimilated to financial income or expenses.
The DGT's position remains constant regarding the nature of financial expenses and their subjection to the limitation of article 16 of the LIS. Throughout the rulings, the deductibility of specific concepts such as late payment interest, loans for goodwill, or joint account contracts has been clarified, always maintaining the requirements of accrual and substantiation.
Turning points
-
Establishes that late payment interest has both a financial and compensatory nature, making it deductible as a financial expense subject to the limits of article 16 of the LIS.
-
Determines that the results of joint account contracts must be fiscally assimilated to financial income or expenses.
Analysis based on 54 of 61 rulings with a stated position. Updated 23 September 2026.