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A company has requested clarification on when VAT should accrue for the purchase of mining rights involving a mixed price (fixed and variable) and deferred payments. The DGT has ruled that accrual occurs upon administrative authorisation or, if advance payments are made, at the time of each collection.
Cuestión planteada Devengo del Impuesto sobre el Valor Añadido.
La transmisión de la concesión administrativa es una prestación de servicios. El devengo se produce cuando se obtiene la autorización administrativa de transmisión. Si existen pagos anticipados antes de dicha autorización, el impuesto se devenga en el momento de cada cobro. Al ser un precio variable, se debe fijar una base imponible provisional que podrá rectificarse cuando se conozca el importe definitivo.
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