It was also regulated by a transitional provision when the reversion should occur: basically and simplifying, when the value of equity of the investee at year-end exceeded the value of equity at the beginning. With RDL 3/2016, a new reversal was introduced, which in essence constitutes a minimum annual reversal amount.
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The criterion of the Directorate General of Taxes in relation to the deductibility of the expenses linked to immovable properties in expectation of rent is very clear in the scope of the Tax on the Income of the Physical Persons. The criterion of the General Directorate of Taxes, until October 3, 2016, has been more ambiguous.