Doctrine by topic · DGT Observatory

Enforcement Period: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Stable position High confidence 11 rulings · 2014–2026

Current position

The enforcement collection period begins the day after the deadline set by the tax regulation expires. During this period, the taxpayer may settle the debt in full or in part. A request for suspension with guarantees other than those for automatic suspension does not prevent the Administration from continuing its proceedings, although its subsequent granting will annul the acts carried out after the request.

The DGT's position remains stable regarding the nature of the enforcement period and the debtor's powers. Rulings have increasingly specified operational aspects such as the start of the period following supplementary self-assessments, the management of partial payments, and the consequences of requests for suspension with special guarantees.

Turning points

  1. V0166-21

    Specifies that partial payment between the assessment and the enforcement order reduces the amount of the enforced debt without requiring a new assessment.

  2. V3301-23

    Establishes that requesting a suspension with guarantees other than automatic ones does not stop the Administration's proceedings, although its subsequent granting annuls the actions taken.

Analysis based on 11 of 11 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

11
V0672-22 28 Mar 2022

No new surcharge applied to unpaid executive surcharge

SG de Tributos Locales
recargo ejecutivorecargo de apremioperíodo ejecutivoprocedimiento de apremiodeuda tributaria TRLRHL — RDLeg 2/2004 de Haciendas Locales art. 10TRLRHL — RDLeg 2/2004 de Haciendas Locales art. 12
Affects CompanyExpat · Non-residentIndividual
Email
Contact