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A query was raised regarding whether initiating a special review procedure for absolute nullity results in the loss of reductions for settlement or prompt payment. The DGT ruled that this procedure is not considered an appeal or claim for the purposes of losing such reductions.
Cuestión planteada
El procedimiento de declaración de nulidad de pleno derecho no se subsume en el concepto de "recursos y reclamaciones" del artículo 188 de la LGT. Al ser un procedimiento extraordinario sobre actos firmes y no un recurso ordinario, su inicio no conlleva la pérdida del derecho a las reducciones por conformidad o por pronto pago.
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