Tax procedures

Analysis and technical assistance in tax procedures.

A tax procedure is won through method: control of deadlines, a full reading of the file, and submissions that combine evidenced facts, procedural defects and legal reasoning. This is a core area of the practice.

Management, review and audit

  • Requests for information and documentation.
  • Limited review and data verification procedures.
  • Audit proceedings: agreed and contested audit reports.
  • Assessment proposals and final assessment decisions.

Penalty proceedings

  • Individualised reasoning of culpability and the prohibition of strict liability.
  • Reasonable interpretation of the rule and due diligence.
  • Proportionality, ne bis in idem and the unity of the infringement.
  • Right to be heard, lapse of proceedings and enforcement of penalties.

Administrative and economic-administrative review

  • Applications for reconsideration and hierarchical appeals.
  • Economic-administrative claims before the regional tribunals (TEAR) and the central tribunal (TEAC).
  • Completeness and transmission of the administrative file.
  • Enforcement of economic-administrative decisions.

Collection and suspension

  • Enforcement orders and enforced collection.
  • Suspension of assessments, guarantees and bank guarantees.
  • Limitation periods and refunds of undue payments.
  • Claims relating to local taxes and charges.

Scope of the work

The work is carried out at administrative and economic-administrative level: analysis of the file, strategy, technical preparation of submissions and organisation of the evidence, where legally appropriate.

Any subsequent court proceedings — judicial review before the administrative courts and further instances — is a different field requiring court representation and advocacy. Those activities are not offered as an own service and must be handled by the corresponding admitted professional.


How the work is done

  1. A full reading of the notice and the file to identify the real core of the dispute.
  2. A line of argument that does not rest on a single point: substantive, procedural and evidentiary.
  3. Strict control of deadlines and of the requirements of each review route.

Documentation usually required

Notices and proofs of service, the administrative file, filed tax returns, accounting records and registers where applicable, contracts and invoices, and the specific evidence on the disputed fact.

Act 58/2003 (General Tax Act) and its implementing regulations (management and audit, collection, administrative review and penalties); Act 39/2015; Act 29/1998 (administrative court procedure).

Work is carried out on the basis of the facts and documentation provided. Where a matter requires activities reserved to qualified professionals — in particular court representation and advocacy — it must be handled by the corresponding admitted professional.

Do you currently have a tax procedure under way? You can set out your case so that it can be assessed.

Submitting the form does not mean the matter has been accepted.

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