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Practical Manual of Companies 2022.

Insufficient taxable base

In the event that the tax base is insufficient to apply the reduction, the pending amounts may be applied in the tax periods ending in the 2 immediate and successive years at the end of the period tax period in which the right to reduction has been generated, together with the reduction that may correspond, if 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 capitalization reserve, when there are amounts pending to be applied from previous periods together with that generated in the period itself, the taxpayer You can apply them in the order you want , 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).