On 10 October 2026, the Central Economic-Administrative Tribunal (TEAC) ruled in favor of a self-employed taxpayer who issued a rectification invoice (factura rectificativa) after the statutory deadline due to a client’s bankruptcy. The TEAC accepted the late filing because the taxpayer proved the debt was uncollectible and complied with all other formal requirements. This opens the door for VAT recovery in insolvency scenarios even when deadlines are missed.
Key Takeaways
- Exception to Deadline: The four-year deadline for rectification invoices (Art. 80 VAT Law) can be extended if the delay is justified by force majeure or third-party insolvency.
- Proof Requirements: Taxpayer must demonstrate the client’s bankruptcy declaration, the impossibility of collection, and the correlation between the original invoice and the rectification.
- Practical Impact: Self-employed with bad debts from bankrupt clients should issue rectification invoices promptly upon insolvency declaration, even if past the usual deadline.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement
