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V3502-15 13 November 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · ajuste de auditoría

Prior year income from audit adjustments must be recognised in the period they accrued

The query examines whether audit adjustments affect outstanding tax loss carryforwards. The DGT rules that income or credits to reserves from previous years must be recognised in the tax period in which they accrued, via a supplementary tax return.

The question raised

Whether audit adjustments have any tax implications and affect pending negative tax bases to be carried forward.

The DGT's ruling

If an audit adjustment determines the recording of income or a credit to reserves from a previous year, it must be imputed to the tax period in which it accrued, pursuant to Article 19.1 of the TRLIS. The regularization must be carried out through the submission of the corresponding supplementary tax return for the period in which the accrual occurred, in accordance with Article 122.1 of the LGT.

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