Skip to content
Back to index
V3103-20 16 October 2020 · SG de Tributos Criterion in force
OTRO · nulidad de pleno derecho

Commencement of an absolute nullity proceeding does not result in the loss of penalty reductions

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.

The DGT's ruling

The procedure for declaring nullity by operation of law does not fall under the concept of "appeals and claims" set forth in Article 188 of the General Tax Law. As it is an extraordinary procedure regarding final acts and not an ordinary appeal, its initiation does not entail the loss of the right to reductions for settlement or for prompt payment.

Book your free first meeting