Question juridique clé
Whether social security back payments for 2001-2003 could be deducted in the 2004 tax year
Solution extraite
No. The amounts belonged to the earlier periods and could not be shifted to 2004; the omission could not be cured later under the period principle.
Motifs extraits
The contributions were clearly attributable to the respective periods and should have been recorded and claimed then. The company's own reporting failures and lack of timely correction did not justify an exception.