The Revenue Agency stated that the failure to file the consolidated financial statements in the Register of Companies prevents the direct assumption of the obligation to guarantee the credit surpluses transferred by the companies and offset in the VAT settlement procedure of group.
In the context of group VAT settlement, the provision of the guarantee within the deadline for submitting the related annual VAT return represents a constitutive element for the completion of intra-group VAT compensation. In the event of late provision of the guarantee, the offsets made in the group still produce their effects, but only from the date on which the obligation (which, as already mentioned, has a constitutive nature) was fulfilled.
This was highlighted by the Revenue Agency with its response to ruling no. 330 of 21 June 2022.
Sources:
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