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Accrued Quotas: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2026

Current position

Under the simplified regime, the amount to be paid is the higher of the difference between current quotas and the minimum quota, adding to the latter the quotas for self-supply (inversión del sujeto pasivo) and intra-Community acquisitions of goods. Quotas accrued due to self-supply must be included in the quarterly return or, optionally, in the return for the final period of the tax year. The obligation to submit Form 349 for intra-Community acquisitions of services remains.

The DGT's position remains stable regarding the treatment of quotas in the simplified regime. Rulings confirm that quotas for self-supply are added to the regime's quota and that the taxpayer may choose the timing of their deduction. No doctrinal changes are observed, but rather a reiteration of the calculation mechanics and formal obligations.

Turning points

  1. V0098-22

    Specifies that quotas for transfers of investment goods do not count towards the calculation of the magnitude based on volume of income in the simplified regime.

Analysis based on 8 of 8 rulings with a stated position. Updated 13 October 2026.

Rulings on this topic

8
V1153-22 26 May 2022

Requirement to include passive shareholder shares in Form 303 and submit Form 349

SG de Impuestos sobre el Consumo
régimen especial simplificadoinversión del sujeto pasivoadquisiciones intracomunitarias de serviciosdeclaración recapitulativacuotas devengadas LIVA — Ley 37/1992 del IVA art. 123.Uno.ALIVA — Ley 37/1992 del IVA art. 123.Uno.B.2
Affects CompanyExpat · Non-residentIndividual

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