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V2377-25 9 December 2025 · SG de Tributos Locales Criterion in force
OTRO · icio

Fiscal ordinance determines whether licence fee deduction applies to full or reduced ICIO rate

The DGT confirms that the fiscal ordinance specifies whether the licence fee deduction applies to the full or reduced ICIO rate.

The question raised

It is asked whether the deduction, where applicable, can be applied to the gross tax liability or, if it exists, must be applied to the subsidized tax liability.

The DGT's ruling

The tax ordinance is responsible for establishing whether the deduction provided for in Article 103.3 of the TRLRHL is applied to the gross tax liability or to the subsidized tax liability. Likewise, the ordinance may regulate other substantive and formal aspects of this deduction. The taxpayer may deduct the amount of the fee in accordance with the provisions of the corresponding tax ordinance.

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