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Practical manual for Income Tax 2023.

Other imputation criteria proposed by the taxpayer

Regulations:Arts.11.2 LIS ; 1 and 2 of Regulation IS

The fiscal effectiveness of criteria for the temporary allocation of income and expenses other than accrual, used exceptionally by the taxpayer to obtain a true image of the assets, financial situation and results of its economic activity, is subject to their approval by the tax authorities.

To this end, taxpayers must submit an application to the Delegation corresponding to their tax domicile, which must include a description of the criteria used, as well as its compliance with the principle of true and fair view that the annual accounts resulting from their accounting must provide.

Likewise, the taxpayer must explain the impact, for tax purposes, of the temporary imputation criterion.

Note: The use of tax imputation criteria other than accrual or the change in the imputation criteria may not alter the tax classification of the computable income and deductible expenses, nor cause any collection or payment to cease to be computed or to be computed again in another fiscal year.