Deducibilità dei costi ed esercizio di competenza – “Il concetto non è opinabile”
Quante volte ci siamo trovati nella situazione di dover valutare la competenze di costi per servivi relativi a fatture infrannuali?
A risolvere ogni dubbio ci viene in aiuto una sentenza della corte di cassazione datata 06/05/2015, la quale, ha confermato un principio ben preciso:
“I costi dei servizi sono deducibili nell’anno in cui la prestazione è portata a termine, a prescindere dal momento in cui viene emessa la fattura o è effettuato il pagamento”
Infatti, le regole sull’imputazione temporale dei componenti del reddito sono tassative e inderogabili, non essendo consentito al contribuente di ascrivere a proprio piacimento un componente positivo o negativo del reddito a un esercizio diverso da quello individuato dalla legge come “esercizio di competenza”.
Nello specifico, la Corte di cassazione, con la sentenza del 6 maggio 2015 n. 9068, ribadisce quanto più volte affermato in tema di determinazione del reddito d’impresa.
I costi dei servizi sono deducibili dalla società nell’esercizio in cui la prestazione viene ultimata, a prescindere dal momento in cui viene emessa la fattura ed effettuato il pagamento, indipendentemente dal fatto che la quantificazione, in termini monetari, sia oggettivamente determinabile.
LA VICENDA PROCESSUALE
Una società, esercente l’attività di commercio di autoveicoli, ha impugnato tre avvisi di accertamento, relativi a imposte dirette per gli anni 1999 – 2000 – 2001 e un quarto avviso relativo a Iva e imposte dirette relative al 2002.
I ricorsi, successivamente, sono stati riuniti innanzi alla Ctp, per connessione oggettiva e soggettiva.
L’ufficio ha contestato la deducibilità di costi per prestazioni di servizi vari e spese pubblicitarie e promozionali, nonché la deducibilità di talune quote di ammortamento.
Nello specifico, è emerso che la contribuente aveva addebitato i predetti costi in anni diversi rispetto a quanto previsto dall’articolo 75 del Tuir (oggi articolo 109), secondo il quale le spese di acquisizione di servizi si considerano sostenute alla data in cui le prestazioni sono ultimate.
La società ha opposto di aver rinviato la deducibilità del costo al momento in cui aveva conosciuto l’esatta quantificazione dello stesso per tutti gli anni delle prestazioni e, dunque, di aver correttamente operato, in quanto, non disponendo delle relative fatture, la certezza del costo si sarebbe determinata solo sulla base del cosiddetto “progetto di notula”.
In sostanza, oggetto del contendere è l’interpretazione del concetto di competenza fiscale, intesa come deducibilità dei costi per prestazioni di servizi, limitata al momento di ultimazione della prestazione, indipendentemente dal fatto che la sua quantificazione in termini monetari sia oggettivamente determinabile.
LA DECISIONE DELLA CASSAZIONE
Con la sentenza in commento, la Cassazione ha ribadito che i costi relativi a prestazioni di servizio sono, ai sensi dell’articolo 109 del Tuir, di competenza dell’esercizio in cui le prestazioni medesime sono ultimate, senza che abbia rilievo alcuno il momento in cui viene emessa la relativa fattura o effettuato il pagamento. La Corte precisa che l’unica eccezione ammessa alla regola generale opera per i contratti di locazione, mutuo, assicurazione o altri accordi da cui derivino corrispettivi periodici, in relazione ai quali le spese per i corrispettivi sono imputabili all’esercizio di maturazione degli stessi (cfr Cassazione 9096/2012).
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