Author: Jesús Cudero

The CJEU strengthens control over the refusal of national judicial bodies to refer questions for a preliminary ruling
The court states that courts of last instance must give adequate reasons for their decision not to refer a question for a preliminary ruling, even in the absence of an express request from the parties. In its recent judgment of 24 March 2026 (Case C-767/23), the Court of Justice of the European Union (CJEU) examines […]

The spanish Supreme Court outlaws the tax authorities’ “third shot”
According to the court, where an assessment is set aside the tax authorities only have a second chance to issue a new administrative measure, regardless of the reasons for ordering it to be set aside. On September 29, 2025, the Supreme Court issued a decisive judgment on second and subsequent assessments by the tax authorities, […]

What is the procedural logic of the so-called double shot in the tax area
Following two recent Supreme Court rulings that support the right of the Administration to review tax obligations for a second time when the administrative act issued in the first place has been annulled, it is worth reflecting on the limits of this double shot. There are issues in the application of the tax system that […]
