Tax penalties
Reasoning of culpability, reasonable interpretation of the rule, proportionality and limits on repeated penalties.
In preparation
Tax Procedures Observatory
An editorial space devoted to the questions that recur in tax procedures: what the rules require, what administrative doctrine has been holding, and where the disputes concentrate.
The Observatory is built on primary sources — consolidated legislation, decisions of the central tax tribunal and Supreme Court case law — and progresses through completed publications rather than volume. Each entry states its date, its last review and the sources used.
Categories
Review and audit
Information requests, scope of proceedings, assessment proposals and the evidentiary value of the file.
In preparation
Appeals and claims
Reconsideration versus economic-administrative claim, deadlines, standing and enforcement of decisions.
In preparation
Collection and suspension
Enforcement orders, guarantees, suspension of assessments and refunds of undue payments.
In preparation
Open lines of work
Questions currently being worked on. They are not published until they are complete and verified against primary sources.
- Reasoning of culpability in tax penalties.
- Information requests from the tax authorities: scope and limits.
- Assessment proposals: content, deadlines and technical response.
- Reconsideration versus economic-administrative claim.
- Suspension of assessments and guarantees.
- Annulment of assessments and material errors.
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.