Spain Supreme Court Confirms Full Regularisation Principle in VAT Refund and Audit Procedures

• Spain’s Supreme Court confirmed the “full regularisation” principle applies in VAT matters, requiring tax authorities to fully assess both favorable and unfavorable outcomes for taxpayers during audits.
• Tax authorities must evaluate if a taxpayer is entitled to a refund of undue VAT payments without requiring a separate procedure.
• The decision prevents double taxation and upholds principles of neutrality, good administration, efficiency, and proportionality.
• The principle applies to both limited and full audit procedures.
• The court’s decision is supported by existing jurisprudence and obliges tax authorities to correct tax situations in a single procedure.

Source: bdo.global

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

---

---