Spanish tax procedure is governed by the General Tax Act (LGT) and its implementing regulations. It frames the formal channels through which the Spanish tax authority verifies, assesses, collects, sanctions and reviews tax obligations, and through which the taxpayer challenges administrative action.
Verification proceedings run through three main routes: the limited verification (with restricted tools and a 6-month maximum), the full inspection (broader investigative powers, with a general 18-month deadline, extendable to 27) and the valuation audit. According to consolidated Supreme Court doctrine, the self-assessment is not an administrative act and therefore is not reviewable under Article 217 LGT.
The administrative appeals route runs through the optional recourse before the issuing body, and the economic-administrative claim before the regional TEAR or the central TEAC, depending on the amount in dispute. Once exhausted, the taxpayer reaches the contentious-administrative jurisdiction, where the Supreme Court has issued substantial doctrine on burden of proof, the principle of good administration, statement of reasons and the statute of limitations.
The limitation period for assessment (4 years) and for sanctioning (4 years) can be interrupted by actions formally notified to the taxpayer; an unjustified interruption of more than 6 months voids the interruption.
This section covers procedural developments, Supreme Court doctrine on review, TEAC case law and strategy in dealing with AEAT actions.