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Tax advisor: If the judgment does not rule on the legal conformity of the act, the limit that prevents the special review of acts confirmed by final judgments does not apply

The interpretation of articles 106 and 47.1.f) of Law 39/2015 (Common Administrative Procedure Act) together with article 222 of the Civil Procedure Act, allows concluding that the ex officio review of an administrative act, which has been declared produced by positive silence in a final judgment, is not prevented by the positive effect of res… Continue reading Tax advisor: If the judgment does not rule on the legal conformity of the act, the limit that prevents the special review of acts confirmed by final judgments does not apply