- The Supreme Court ruled that full regularization does not apply when the Administration has previously regularized VAT in a deed of conformity, resulting in a final liquidation.
- Signing a deed of conformity and final liquidation prevents taxpayers from requesting deduction of amounts supported by other means.
- The Supreme Court based its decision on the following:
- The deed of conformity is final.
- Challenging a liquidation from a deed of conformity requires proof of an error of fact or law.
- Full regularization is not applicable when a previous procedure has determined the VAT supported.
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.
