How the DGT's position has evolved
Current position
Expenses are tax-deductible for Corporate Income Tax (IS) provided that the requirements of accounting recognition, accrual, correlation with income, and documentary justification are met. They must not be considered non-deductible expenses under the Corporate Income Tax Law. Accrual must be carried out in accordance with current accounting standards.
The DGT's position has remained constant over time. All analyzed rulings, from 2014 to 2026, reiterate that the deductibility of expenses is subject to compliance with the requirements of accounting accrual, accrual, and documentary justification.
Analysis based on 28 of 31 rulings with a stated position. Updated 24 September 2026.