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Modification to the IRAE and IP liquidation criteria

Modification to the IRAE and IP liquidation criteria

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Through Resolution No. 1,435/2021, the General Tax Directorate provides for the modification of the liquidation criteria for the IRAE (Impuesto a las Rentas de Actividades Económicas – Income Tax on Economic Activities) and IP (Impuesto al Patrimonio – Wealth Tax) concerning the extension of the established deadlines.

1. Background

Through Resolution No. 2062/2008, the DGI (Dirección General Impositiva – General Tax Directorate) establishes the liquidation criteria for Taxes in cases of overlapping of generating facts.  

For example, the aforementioned regulation established liquidation criteria for the Income Tax on Economic Activities and Wealth Tax to apply in cases where the same taxpayer generates income derived from agricultural activities along with other income.

However, in view of the successive modifications, it is considered necessary to adjust the criteria established in the aforementioned resolution and the terms set forth therein were extended to maintain a harmonious Tax System.

2. Amended provisions

A. Section 1° of Resolution No. 2062/2008 is hereby replaced by the following:

Separate liquidation

Taxpayers of the Income Tax on Economic Activities and Wealth Tax, obtaining income derived from agricultural activities along with other income comprised in the first of the aforementioned taxes, may liquidate the taxes corresponding to the agricultural activity separately from those derived from the rest of their taxed activities for economic years ending prior to July 1, 2022

B. Section 3 of Resolution No. 2062/2008 of December 19, 2008, is replaced by the following:

Closing of the fiscal year

According to the provisions of Article 8 of Title 4 of the Amended Text 1996, taxpayers included in this resolution shall liquidate the IRAE corresponding to all their activities as of June 30 of each year as of July 1, 2022

When the DGI has authorized a closing date different from June 30, the liquidation of all activities shall be made as of such date for fiscal years starting as of January 1, 2022.

C. Section 4 of Resolution No. 2062/2008 of December 19, 2008, is replaced by the following:

Transition

For non-agricultural activities, taxpayers who have made their tax liquidations under the provisions of section 1) shall make the closing of the fiscal year as of June 30, 2022, for each of their activities, liquidating the corresponding taxes.

En los casos en que la DGI haya autorizado una fecha de cierre de ejercicio diferente al 30 de junio, el cierre de ejercicio fiscal para cada una de sus actividades se realizará a dicha fecha.

If the DGI has authorized a closing date different from June 30, the closing will be executed at that date for each activity.

Source: Diario Oficial 08/09/21

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