In its recent ruling on October 2, 2023, the Supreme Court has declared the following doctrine: “1. The subsidiary tax liability under Article 43.1.a) of the LGT has a punitive nature. Such punitive nature does not prevent the legislator, within constitutional limits, from modulating the inapplicability regime of punitive acts, including those based on the… Continue reading Tax advisor: The Supreme Court rules that the subsidiary liability under Article 43.1.a) of the LGT has a punitive nature