COVID-19: Ordinary time periods still apply for filing central government tax returns

From a tax perspective, the following measures should be noted:

1. The regime for deferred payment of tax debts in the context of central government taxes for small and medium-sized companies and the self-employed, specified in Royal Decree-Law 7/2020, of March 12, 2020. This regime allows payment to be deferred for six months, and without interest in the first three, of debts resulting from tax returns and self-assessments with filing and payment periods ending between March 13, 2020 and May 30, 2020, and which do not exceed 30,000 euros; this includes debts in respect of withholdings, charged taxes and corporate income tax prepayments. See our alert (here).
2. The suspension of time limits and the interruption of time periods under procedural laws for all jurisdictions (including tax), under Royal Decree 463/2020, of March 14, 2020, declaring the state of emergency, subsequently amended by Royal Decree 465/2020, of March 17, 2020. See our alert (here).
3. The measures introduced by Royal Decree-Law 8/2020, of March 17, 2020 (Alert), notably:
          
   
   1. Extension until April 30, 2020, or until May 20, 2020, of payment periods of the tax debts assessed in the voluntary period and in the enforcement period, and of the expiry dates for time periods and split payments under deferred and split payment agreements, according to whether they have been assessed or granted before or after the declaration of the state of emergency.
   2. Extension until the same dates of the time periods for fulfilling certain official requests, procedures and requests for information or for filing submissions in certain proceedings.
   3. Suspension of the running of the maximum length of tax application, penalty and review procedures conducted by the State Tax Agency until April 30, 2020, although the tax authorities may set in motion, order and carry out any essential steps.
   4. Suspension of the running of statute of limitations periods and of time bars also until April 30.

The listed  measures have been amended or clarified by the recent Royal Decree-Law 11/2020, of March 31, 2020 (see our alert) which, moreover, has extended those measures to autonomous community and local government procedures and has established specific rules on deferred payment of customs debts.

Despite all of these measures, the periods for filing self-assessments such as the return for corporate income tax prepayments for April 2020, the monthly or quarterly VAT or withholdings returns, the personal income or wealth tax returns, have not been extended.

All of these provisions and those which have been approved by autonomous community governments (some of which have extended the time periods for filing autonomous community tax returns and paying the resulting debts) and other tax-related matters of interest have been summarized in our March alerts, which may be found classified by territories (along with a link to the approved pieces of legislation) on the following Interactive Map (available here).