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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 […]
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This is the Artificial Intelligence Strategy in the Strategic Plan of the Tax Agency
The 2024-2027 Strategic Plan establishes the principles that should guide the use of Artificial Intelligence for the prevention and fight against tax fraud. However, there is a lack of express references to taxpayers’ rights and principles (such as transparency and proportionality, or the principle of non-discrimination) that are widely recognized and whose protection is essential […]
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Time of imputation of refunds of taxes declared unconstitutional
The Constitutional Court has been limiting the temporal effects of the unconstitutionality of tax rules, in the case of non-consolidated situations, to the date on which the corresponding ruling is handed down, with an expansive interpretation of this concept of “non-consolidated situation”. We review what these limitations consist of and how to allocate any refunds […]
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