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Third presentation session on “Tax application procedures”

The presentation of the latest work of Fundación Impuestos y Competitividad, under the title “Current issues concerning tax application procedures and proposals for improvement”, took place at the headquarters of EY in Madrid.

Maximino Linares Gil, partner at EY Abogados and trustee of Fundación Impuestos y Competitividad, and project co-ordinator, delivered the opening remarks.

The session included presentations delivered by the authors of three of the chapters of the work presented, which were the focal point of the session:

  • Procedural litigiousness: causes and proposals for improvement. Speaker Pablo Chico de la Cámara (Universidad Rey Juan Carlos)
  • The tax procedure in recent rulings of the Supreme Court: specifically the principle of good administration. Speaker Sandra González de Lara Mingo (Audiencia Nacional – National High Court)
  • The role of the new appeal for reversal in the formation of case law on tax procedures: the relationship between the order granting leave to proceed and the effects over time of the changes in case law. Speakers Ana M.ª Juan Lozano ( Universidad de Valencia) and Joaquín Huelin Martínez de Velasco (Cuatrecasas)

Later, there was a roundtable discussion, with the participation of the speakers and Diego Loma Osorio (Head of Legal Services at the Spanish Tax Administration State Agency – AEAT), with Maximino Linares Gil acting as moderator.

The presentations, and especially the subsequent exchange of views among the members of the roundtable, highlighted the excessive volume of tax disputes and the advisability of finding solutions to reduce this tension; ineffective for both taxpayers and the actual Tax Administration. In particular, the task undertaken by the Supreme Court in the resolution of said disputes by process of law was discussed in depth, paying special attention to recent rulings on the matter delivered by the Supreme Court, as well as the novelties of the new appeal for reversal, the practical application of which has given rise to new realities, some of them requiring the relevant clarification.

The differing viewpoints of the members of the roundtable sparked an interesting debate, with complementary views on the matter.