Il principio di competenza dopo la riforma degli OIC

Untill a few years ago, the time-based imputation criteria with regards to the relation with third-parties, vendors or buyers of goods & services were exclusively handled through taxations laws. In those cases where different criteria might have been adopted, the taxation laws would have to be changed accordingly, to figure out the fiscal outcome during that time. The justification was having specific fiscal rules, less precise, more approximate, but more focused, in the name of certitude and stability of relationships. Despite this cautiousness, however, the interpretative disputes on time-based recognition have been countless. In recent years the accountable principles have been given relevance, first for the big companies that use international accountable principles, later also for those using national accounting principles. The adoption of accountable rules became necessary to overcome the legal-formal qualification as “assumption” in the TUIR dispositions in favour of an economic-substantive qualification, which is now at the base of detection of company events in financial statements. It is also a sign of a recent understanding of a substantially “different” nature of these issues, normally limited to shifts concerning added value taxation from one period to another compared to tax evasion. The article covers also numerous practical examples of time-based recognition and contains a proposal to definitely overcome uncertainty regarding the border separating costs and incomes to be either selected or not aimed to building up taxable income, considering the of budget approval as limit for “reliable determination” of costs and income of the financial year to date.

il contributo permette di confrontarsi con il nuovo rapporto, in tema di imputazione temporale delle componenti reddituali, fra principi contabili nazionali e fiscalità d’impresa. Il tema suscita riflessioni abbastanza simili a quelle indotte a suo tempo dalla fiscalità degli IAS e permette più in generale di fare il punto sul principio di competenza e il suo ruolo nella fiscalità d’impresa del futuro.