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The taxpayer inquired whether they could attribute expenses to subsequent financial years following a tax authority correction, and whether they could file a supplementary tax return to obtain a larger refund. The Directorate-General for Taxes (DGT) ruled that expenses already recorded cannot be reallocated, and that neither supplementary self-assessments nor rectifications are permissible once a final assessment has been issued.
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No procede la imputación en otro ejercicio de gastos contabilizados en el periodo legalmente procedente y anulados por comprobación, salvo lo previsto en el artículo 11.3.1º de la LIS. La presentación de declaraciones complementarias solo procede si resulta un importe a ingresar superior o una devolución/compensación inferior. No cabe la modificación de un acto declarativo que ya ha sido objeto de liquidación definitiva por la Administración.
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