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V1511-22 ·24 June 2022 ·consulta-vinculante Medium impact
Tax

I+D+i deductions not declared in 2010-2018: cannot be claimed in uns prescribed periods if generation periods are already prescribed

A hotel group conducted a technology innovation project between 2010 and 2018 but failed to claim the article 35 LIS deductions in any generation period. The DGT applies the repeated TEAC doctrine from March 2022, concluding that deductions arising in prescribed periods cannot be claimed in non-prescribed periods, as this would breach the principle of prescription. Rectification of self-declarations is possible in non-prescribed periods. In restructurings under Chapter VII of Title VII of the LIS, the acquiring entity assumes the transferor's rights if all conditions in article 84 LIS are met.

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2022-06-24PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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