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A public-owned commercial entity engaged in radio and television broadcasting sought clarification regarding the deductibility of input VAT. The Directorate-General for Taxes (DGT) clarifies that, when performing both taxable and non-taxable activities, a reasonable imputation criterion must be applied to goods and services used for both purposes.
Question raised: Deductibility of VAT paid.
Taxable persons who jointly carry out taxable and non-taxable operations pursuant to Article 7.8 of Law 37/1992 may deduct the input tax on goods and services intended simultaneously for both through a reasonable and homogeneous imputation criterion. Tax amounts for acquisitions intended exclusively for non-taxable operations shall not be deductible in any proportion. The imputation criterion must be maintained over time except for reasonable causes for its modification.
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