Forward or deferred price transactions

Article 11.4 of the LIS establishes that in the case of installment or deferred price transactions , the consideration for which is payable, in whole or in part, through successive payments or a single payment, provided that the period between the accrual and the due date of the last or only installment is longer than one year, the entity must impute the aforementioned income proportionally as the corresponding collections become due in application of the criterion of exigibility of collections, except that said entity decides to apply the accrual criterion , in which case it must impute all of the corresponding income to the period in which it was accrued.

In the event of an endorsement, discount or advance collection of the deferred amounts, 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] "Installment transactions (art. 11.4 LIS)" page 12 of form 200, the positive or negative differences arising between the profits recorded in the profit and loss account for the year being declared and the amounts that are tax-accountable for such concepts, relating to installment transactions or deferred price transactions, for which the taxpayer has opted for a temporary imputation criterion for tax purposes different from that applicable under accounting rules, must be recorded.

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

Pursuant to the provisions of the preceding paragraph, in the event that the taxpayer has chosen to include in the tax base the income generated proportionally as the collections become due, if when the deadline for collecting the deferred amount expires and it is not collected, said income, provided that the requirements for its deductibility are met in accordance with the provisions of article 13 of the LIS, must be included in the tax base independently of the collection, with the portion of the impairment of value that has been recorded being also deductible, in the part that corresponds to that uncollected amount.

Therefore, since the tax deductibility of the impairment of the value of 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 proceed.

Transitional regime for instalment or deferred price operations

The first transitional provision of the LIS establishes a transitional regime for installment transactions, according to which in the case of installment or deferred price transactions carried out in tax periods beginning before January 1, 2015 , income pending integration in tax periods beginning on or after that date will be integrated into the tax base in accordance with the tax regime that was applicable at the time the transactions 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, installment transactions or deferred price transactions, for which the taxpayer has opted for a temporary imputation criterion for tax purposes different from that which would be applicable under accounting rules, must be entered in boxes ##1## [00510] and [00512] "Installment transactions ( ##2## DT ##2## 1 LIS)" ##1## on page 13 of form 200.