Solutions on fiscal appeals
Zusammenfassung
The fiscal authorities that deal with solving the fiscal appeals issue decisions through which they order the annulment of the act of fiscal taxes and the issuing of a fiscal administrative act by re-assessing the situation de facto which was the basis of establishing the basis to be taxed, without mentioning if the appeal has been admitted, totally or partially and without deciding on the effects that come as a result of the decision issued. Such a decision may put the subordinate fiscal authorities at an advantage in relation to the claimant, even if there are not any other findings or extra information, most of the times violating the principle of the fiscal control being unique for the same tax and the same fiscal period of time.