The Central Economic-Administrative Tribunal (TEAC), in its decision of 25 March 2026 (extraordinary appeal for unification of criterion no. 5861/2025), confirms that a tax notification made at the contributor’s tax domicile, despite the prior designation of a representative with a domicile for notifications, is not automatically invalid in an ex officio procedure. If the notification meets its proper purpose —reaching the contributor’s effective knowledge within a useful period—, it operates in full. The dies a quo of the time limit to appeal is counted from the date of the notification, not from the material delivery by the third party. The doctrine qualifies the Spanish Supreme Court’s criterion (judgments of 7 October 2015 and of 1 July 2025) under the rule of purpose achieved.
The practical consequence, for defensive purposes, matters especially in inspection or management procedures initiated ex officio. The designation of a representative does not shield the contributor against a silent computation of the time limit if the notification meets its communicative function. It is advisable to maintain traceability of the communications received at the tax domicile and at the representative’s domicile, articulate an internal reception protocol that minimises the risk of the notification being left unprocessed and, where applicable, formalise the designation of the representative with the greatest possible clarity so that the acting body attends to it. The difference between preserving the time limit to appeal intact or exhausting it without reaction may depend, in practice, on that internal protocol.