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The taxpayer asks whether product losses in tax warehouses must be determined by their tax heading, regardless of their nomenclature code or commercial name. The DGT responds that the calculation must be carried out in accordance with the tax treatment provided for each heading.
Question posed The applicant asks how the losses of products occurring during their storage should be determined, and whether it is correct to determine them based on the tax heading, regardless of the combined nomenclature code or the commercial name of the product stored in the tax warehouse.
Losses from the storage of hydrocarbons must be calculated in accordance with the tax treatment provided for in the regulation for each of the various tax headings. This calculation must be carried out regardless of the combined nomenclature code or the commercial name of the product stored in the tax warehouse. If there are products with identical tax treatment, the quantification of losses must be made taking into account the totality of said products.
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