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A taxpayer inquired whether they must report and withhold new payments to a supplier following a precautionary attachment of their credits. The Directorate-General for Tax (DGT) ruled that only credits that have already accrued but have not yet reached maturity, or those involving successive payments under continuous performance contracts or ongoing relationships, are subject to attachment.
This ruling clarifies the scope of precautionary attachments, limiting their application to existing obligations or ongoing contractual relationships, thereby protecting future or unaccrued credits from immediate seizure.
The tax team reviews your specific situation.
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