Forward or deferred price transactions

article 11.4 of the LIS establishes that in the case of installment operations or with deferred price , whose consideration is payable, in whole or in part, through successive payments or through a single payment, provided that the period elapsed between the accrual and the expiration of the last or only installment is greater than one year, the entity must allocate the aforementioned income proportionally as the corresponding charges are due in application of the criterion of enforceability of the charges, unless said entity decides to apply the accrual criterion , in which case it must allocate all of the corresponding income to the period in which it was earned.

In the event that the endorsement, discount or advance collection of the deferred amounts occurs, the income pending imputation will be deemed to have been obtained at that time.

Filling in form 200

In application of the above, in boxes [00357] and [00358] "Instalment transactions (art. 11.4 LIS)" on page 12 of form 200, the differences must be recorded positive or negative differences that arise between the profits recorded in the profit and loss account of the year being declared and the amounts that are taxable for such concepts, referring to installment operations, or with deferred price, with respect to which the taxpayer would have opted for a temporary imputation criterion for tax purposes different from that applicable under the accounting rules.

Furthermore, article 11.4 of the LIS establishes that the impairment in value of credits will not be tax deductible with respect to that amount that has not been included in the tax base by application of the criterion on the installment operations established in this section, until this is carried out.

According to the provisions of the previous paragraph, in the event that the taxpayer has chosen to integrate into the tax base the income generated proportionally as the collections become payable, if upon expiration of the period to collect the deferred amount it is not collected, Said income must be integrated into the tax base regardless of collection, with the part of the impairment that has been recorded also being deductible in the part that corresponds to that uncollected amount.

Therefore, as the tax deductibility of the deterioration in value of the credits generated by term operations is deferred until the moment in which the income is integrated into the tax base, in application of this principle the taxpayer must make in these boxes [00357] and [00358] the adjustments to the accounting result that apply.

Transitional regime for operations in installments or with deferred price

The first transitional provision of the LIS establishes a transitional regime for installment operations, according to which in the case of installment operations or with deferred price carried out in tax periods started prior to January 1, 2015 , income pending integration in tax periods starting on that date will be integrated into the tax base in accordance with the tax regime that will be applicable at the time of that the operations were carried out, even when the integration is carried out in tax periods beginning after January 1, 2015.

In application of the provisions of this transitional provision, "Instalment transactions ( DT 1 LIS)" ## must be entered in [00510] and [00512] ##1##on page 13 of form 200, the positive or negative differences between the profits recorded in the profit and loss account of the year being declared and the amounts that are taxable for such concepts, referring to installment operations, or with a deferred price, with respect to which the taxpayer had opted for a temporary imputation criterion for tax purposes different from that which would be applicable under the accounting standards.