El fondo de educación y promoción y su impacto en la tributación de las cooperativas

Resum

One of the tools used by cooperatives to comply with the requirements of the 5th cooperative príncíple, related to information, training and cooperative promotion, is the Education and Promotion Fund. Said Fund constitutes an internal reserve for specific legal purposes related to education and promotion of cooperatives, and which has a significant impact on the tax regime of cooperatives. Firstly, the breach of the duties of endowment of said Fund, proper accounting and use of its amount for legal purposes constitutes a cause of loss of the tax protection inherent to the special regime of this type of Entities. Secondly, the allocations made to it generate a deductible expense in the corporate tax base, which represents an exceptional treatment with respect to the general rule of nondeductibility of allocations to reserves or internal funds.