Settlements during tax litigation, and weight of evidence
Amendments to the tax claim procedure
- Tax Courts are authorized to promote conciliation hearings at any time during the first instance stage.
- The filing of an appeal for annulment (“recurso de casación en la forma”) against the first instance judgement issued by the Tax Court is now allowed.
- Tax Courts are obliged to publish their judgments.
- The grounds, on which the appeal for annulment shall proceed against the judgment of second instance is now regulated.
- It is established that, for a single time within a period of 2 years from the publication of the tax reform, taxpayers who have legal proceedings pending could opt to terminate those proceedings by recognizing the existing tax debt. In such cases, a total forgiveness of interest and fines is granted by the IRS.