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V2717-18 10 October 2018 · SG de Tributos Criterion in force
OTRO · embargo de crédito

Attachment of a credit must be for the net amount, deducting payments made on behalf of the supplier

A query was raised regarding whether, when attaching a supplier's credit, the amount of payments already made by the client on behalf of said supplier should be deducted. The DGT rules that the attachment must refer to the total amount due, minus the payments made on the supplier's behalf.

The question raised

In the event that payments have been made on behalf of the supplier, should these be deducted from the existing credit in their favor, such that the amount to be paid to the Tax Administration would be the amount of the purchases made minus the amount of said payments?

The DGT's ruling

The attachment of the credit must be understood as referring to the totality of the amounts that the client must satisfy to the supplier, deducting from the amount of the purchases made the amounts that the client has paid, where applicable, on behalf of the supplier. This is based on the principle that obligations are extinguished by payment.

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