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A radiopharmaceutical company has requested clarification on when VAT should accrue in its continuous supply contracts. The DGT has ruled that, as these are successive performance operations, accrual occurs when each part of the price becomes due in accordance with the contract.
Cuestión planteada Devengo del Impuesto sobre el Valor Añadido de las operaciones objeto de consulta.
Las entregas continuadas de productos bajo un contrato de suministro son operaciones de tracto sucesivo. El devengo del impuesto se produce en el momento en que resulte exigible la parte del precio que comprenda cada percepción. Si no se ha pactado precio o su exigibilidad, el devengo será el 31 de diciembre por la parte proporcional del periodo. La cesión de facturas mediante factoring sin recurso no altera este momento de devengo.
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