The Model 720 after the CJEU judgment
The procedure for claiming Form 720 fines will depend on the situation of each taxpayer: appeals in progress, appeals not lodged but penalties within the deadline for appeal and final penalties.
The procedure for claiming Form 720 fines will depend on the situation of each taxpayer: appeals in progress, appeals not lodged but penalties within the deadline for appeal and final penalties.
The consequences of failure to comply with Model 720 are disproportionate in view of the objectives pursued by the regulatory framework, which are to ensure tax control and the fight against fraud.
The comparability analysis compares the circumstances of the related transactions with those of transactions between independent persons or entities that could be comparable.
The new method for calculating capital gains tax will offer taxpayers the possibility of choosing between two options (objective and real method), being able to opt for the more favorable one, as long as the value of the land undergoes a real increase.
New internal flexibility mechanisms are implemented in companies to avoid dismissals, revising the current model of ERTEs and creating the so-called RED mechanism.