BackIn recent years, the tax procedure has acquired a key importance for taxpayers by ensuring that the tax administration acts within the existing regulatory framework and respects essential constitutional and tax principles, such as fairness, generality, equality and non-confiscation.
These principles, often overlooked, are fundamental to ensure an efficient and fair tax system, protecting taxpayers’ rights against possible abuses or arbitrary interpretations of the law. In this context, the role of the Supreme Court (SC) has been decisive in defining the limits of the State’s taxation power, ensuring that it is exercised in a proportional, non-discriminatory manner that respects fundamental rights.
The SC’s case law has played an essential role in protecting taxpayers’ rights, clarifying procedural guarantees and validating administrative acts in situations of regulatory uncertainty. This has contributed to strengthening the principle of legal certainty in the tax field.
Within this procedural framework, in its ruling of 30 September 2024, the SC reiterates its doctrine on the deadline for agreeing to extend the scope of a limited verification procedure. Specifically, it establishes that such extension must be agreed prior to, and not simultaneously or subsequently to, the communication of the proposed assessment for the taxpayer to submit his or her allegations.
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