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 the close 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.
Note:
When applying the corresponding reduction to the capitalization reserve, when there are amounts pending application from previous periods together with the amount generated in period itself, the taxpayer may apply them in the order he or she wants , since there is nothing established about whether one or the other has to be applied first. (Resolution of the Central Economic-Administrative Court (TEAC) issued on September 22, 2021, in an extraordinary appeal for the unification of criteria).