Tax Advisor: The Supreme Court allows the deduction in the Personal Income Tax of the severance pay of senior managers who are administrators

The Supreme Court, in its ruling number 1092/2023, dated July 25, ECLI:ES:TS:2023:3589, has established as case law the following: 1) It is feasible to apply the reduction for irregular income as established in article 18.2 of the Personal Income Tax Law (LIRPF) to compensation received by senior executives who also hold the position of corporate… Continue reading Tax Advisor: The Supreme Court allows the deduction in the Personal Income Tax of the severance pay of senior managers who are administrators

Tax advisor: Possibility of deducting the remuneration of the directors of a company in the Corporate Tax

The consideration of the deduction as an expense of the partners’ salary in Corporate Tax has been the subject of controversy between the Tax Authorities and the companies, an issue on which the Supreme Court has issued several opinions, although not in an enlightening manner. In the recent Supreme Court Ruling of June 27th (not… Continue reading Tax advisor: Possibility of deducting the remuneration of the directors of a company in the Corporate Tax

Tax Advisor: Compensations granted to directors in Corporate Income Tax cannot be considered as acts of generosity and the theory of the link does not apply to them

In a ruling, the Supreme Court rejects the debate on the deductibility of compensation to directors based on concepts such as liberality and expenses contrary to the legal system, as long as such compensation is duly registered and the rendering of services is not in question. In addition, the court emphasizes its rejection of the… Continue reading Tax Advisor: Compensations granted to directors in Corporate Income Tax cannot be considered as acts of generosity and the theory of the link does not apply to them