- The subject is the regularization of hidden sales for the calculation of the taxable base of the Personal Income Tax (IRPF) when the Value Added Tax (VAT) cannot be regularized due to the expiration of the right to settle.
- The criterion is that when the tax authorities prove the existence of hidden operations in which no mention of VAT is made, the classification of whether the amounts of the operations include VAT or not should be the same for all similar operations, even if some periods of VAT cannot be regularized due to prescription.
Source: serviciostelematicosext.hacienda.gob.es
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.