TEAC Resolutions on IVA Deductions: Temporal Requirements for Exercising Right to Deduct

• Criteria: The “dies a quo” for the calculation of the expiration of the right to deduct is set at the moment of the birth of the right.
• It is necessary to distinguish between the birth of the right to deduct and the exercise of such right. The latter can only be exercised in the tax return for the tax period in which the taxpayer has incurred deductible amounts or in subsequent ones, provided that four years have not elapsed from the birth of said right.
• In this sense, the Supreme Court pronounces in the judgment of February 21, 2012 (appeal n.º 505/2008).

Source: audiconsultores-etlglobal.com

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.

---

---