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Practical Handbook for Companies 2021

Insufficient taxable base

In the event that the taxable base is insufficient to apply the reduction, the outstanding amounts may be applied in the tax periods ending in the 2 years immediately following at the end of the tax period in which the right to the reduction was generated, together with the reduction that may correspond, where applicable, by application of the provisions of this article in the corresponding tax period, and with the limit provided for in the previous paragraph.


When applying the reduction corresponding to the capitalisation reserve, when there are amounts pending application from previous periods together with that generated in the period itself, the taxpayer may apply them in the order he/she wishes, as there is nothing established about one or the other having to be applied first.(Resolution of the Central Economic-Administrative Tribunal (TEAC) issued on 22 September 2021, in an extraordinary appeal for the unification of criteria).