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Voluntary Period: 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 · 2014–2023

Current position

The taxpayer may satisfy the debt in full or in part during both the voluntary and the enforcement periods. Payment in kind is admissible during the voluntary period if provided by law and regulatory requirements are met, provided that the debt is not non-deferrable. Late payment interest on penalties is not required during the voluntary payment period; its calculation begins on the day following the end of said period.

The DGT's position remains constant regarding the nature of the voluntary period as a phase for debt satisfaction. Rulings have clarified specific aspects such as the calculation of the statute of limitations, the possibility of partial payments, and the application of late payment interest. No change in criterion is observed, but rather an application of the regulations to different factual scenarios.

Turning points

  1. V0859-18

    Clarifies that the period for demanding payment of liquidated debts begins on the day following the end of the payment period in the voluntary period.

  2. V1995-23

    Establishes that the calculation of late payment interest on penalties begins on the day following the end of the voluntary payment period.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V0569-15 12 Feb 2015

Cannot change declaration frequency, only debt deferment possible

SG de Impuestos sobre las Personas Jurídicas
aplazamientofraccionamientoperiodo voluntarioretenedorgarantías LGT — Ley 58/2003 General Tributaria art. 65LGT — Ley 58/2003 General Tributaria art. 82
Affects CompanyExpat · Non-residentIndividual
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