Shopping Cart
Your Cart is Empty
Quantity:
Subtotal
Taxes
Shipping
Total
There was an error with PayPalClick here to try again
CelebrateThank you for your business!You should be receiving an order confirmation from Paypal shortly.Exit Shopping Cart

RAÚL GONZÁLEZ GALÁN ABOGADOS



EL TRIBUNAL SUPREMO PROHÍBE A LA AGENCIA TRIBUTARIA LA IMPUTACIÓN COMO GANANCIA PATRIMONIAL DE LOS BIENES EN EL EXTRANJERO SIN PLAZO DE PRESCRIPCIÓN

El Tribunal Supremo, en Sentencia de 20 de junio de 2022, prohíbe a la Agencia Tributaria imputar como ganancia patrimonial los bienes en el extranjero sin plazo de prescripción.

La Sentencia determina que una liquidación por IRPF no puede practicarse sin sometimiento a plazo de prescripción alguno, cuando las ganancias patrimoniales no justificadas que se regularizan correspondan a rendimientos constituidos en bienes y activos en el extranjero y hayan sido puestas de manifiesto con ocasión del cumplimiento extemporáneo de la obligación de información.

Según la Sentencia, la Comisión Europea considera que la previsión contenida en el artículo 39.2 de la LIRPF, introduce un mecanismo manifiestamente desproporcionado de imprescriptibilidad de la potestad de regularizar las rentas de la AEAT. Razona también, que en el ámbito de la Unión Europea, existen mecanismos suficientes de cooperación administrativa para la transmisión de información fiscal.

EL ALCANCE DEL PROCEDIMIENTO DE COMPROBACIÓN LIMITADA POR LA AGENCIA TRIBUTARIA NO PUEDE SER AMPLIADO EN LA APERTURA DEL TRÁMITE DE AUDIENCIA

El Tribunal Supremo, en Sentencia de 3 de mayo de 2022, interpreta que la ampliación del alcance del procedimiento de comprobación limitada, junto con la notificación del trámite de audiencia y propuesta de liquidación, es contraria a los artículos 34.1.ñ) y 137 de la LGT, y constituye causa de nulidad de la liquidación dictada, que debe calificarse como infracción sustantiva del artículo 48.1 de la Ley 39/2015 y no como mero defecto formal.

Novedades

Blog

BEST LAWYERS SPAIN 2016

Posted on October 22, 2015 at 4:08 AM
El socio-presidente de nuestra Firma, D. Raúl González Galán, ha sido recientemente incluido en el Directorio de Abogados de reconocido prestigio "Best Lawyers" Spain 2016.

Categories: NOTICIAS DE LA FIRMA

Post a Comment

Oops!

Oops, you forgot something.

Oops!

The words you entered did not match the given text. Please try again.

171 Comments

Reply air jordan
10:15 PM on June 18, 2022 
I wish to show some appreciation to this writer for rescuing me from such a dilemma. Because of checking throughout the world-wide-web and obtaining views which were not pleasant, I believed my life was well over. Living without the presence of strategies to the problems you have solved by means of this site is a critical case, as well as those that might have in a wrong way affected my entire career if I had not discovered your web site. Your main understanding and kindness in maneuvering the whole thing was tremendous. I don't know what I would have done if I hadn't come across such a stuff like this. I'm able to now relish my future. Thanks for your time very much for the reliable and amazing help. I won't hesitate to endorse your web site to anyone who will need guide about this issue.
air jordan http://www.jordanstoreonline.com
Reply kyrie 7 shoes
10:16 PM on June 18, 2022 
I needed to compose you a little bit of observation just to give many thanks once again over the nice tips you have documented on this page. It has been really unbelievably open-handed of you to deliver unreservedly all a number of people would have supplied as an e book to get some dough for themselves, mostly since you could have done it in case you decided. The tactics additionally acted like a good way to realize that some people have the identical keenness like my very own to figure out a lot more on the subject of this matter. I'm certain there are thousands of more pleasurable opportunities in the future for folks who read through your blog post.
kyrie 7 shoes http://www.kyrie7shoes.us
Reply curry 7 shoes
10:16 PM on June 18, 2022 
Thank you for your entire labor on this web page. My mother delights in setting aside time for investigations and it's really obvious why. My spouse and i hear all relating to the compelling way you provide advantageous techniques via the website and as well inspire contribution from other individuals on that issue and our daughter is undoubtedly starting to learn a whole lot. Have fun with the remaining portion of the new year. You are always performing a really good job.
curry 7 shoes http://www.curry7.us
Reply birkin bag
10:17 PM on June 18, 2022 
I wish to show appreciation to the writer just for rescuing me from this particular problem. As a result of surfing through the world-wide-web and getting things which are not helpful, I believed my entire life was well over. Being alive devoid of the solutions to the problems you've resolved through your write-up is a critical case, as well as those which may have in a negative way affected my entire career if I hadn't come across your web page. Your good talents and kindness in handling all the pieces was valuable. I am not sure what I would've done if I hadn't discovered such a solution like this. I am able to now relish my future. Thanks so much for your high quality and sensible help. I won't hesitate to recommend your blog post to any individual who needs guide on this problem.
birkin bag http://www.hermesbirkins.com
Reply bape
10:17 PM on June 18, 2022 
Thanks for all your work on this web site. My daughter delights in doing investigations and it is easy to understand why. I hear all about the powerful form you create invaluable secrets through your website and even encourage participation from other people on this matter plus my girl has always been starting to learn a lot. Take pleasure in the remaining portion of the new year. You're doing a superb job.
bape http://www.bapehoodie.us
Reply curry shoes
10:17 PM on June 18, 2022 
I needed to draft you that little observation to help thank you very much again for these remarkable advice you have contributed in this article. It's strangely open-handed with people like you to allow extensively all numerous people might have supplied for an electronic book to help make some bucks for themselves, most notably now that you could have tried it in case you desired. These things as well acted to become a good way to fully grasp the rest have a similar desire just like my very own to see a great deal more when it comes to this condition. I'm certain there are many more enjoyable periods up front for individuals that find out your blog post.
curry shoes http://www.curry-shoes.net
Reply hermes birkin
10:17 PM on June 18, 2022 
I just wanted to construct a word in order to thank you for the magnificent recommendations you are placing on this site. My rather long internet research has now been compensated with sensible points to write about with my co-workers. I would point out that many of us website visitors are extremely blessed to live in a magnificent network with very many brilliant professionals with useful opinions. I feel truly happy to have used your web site and look forward to tons of more entertaining moments reading here. Thanks a lot once more for everything.
hermes birkin http://www.birkinbag.us.com
Reply moncler jackets
10:17 PM on June 18, 2022 
I wanted to send a small remark to be able to express gratitude to you for all of the marvelous guidelines you are giving out here. My prolonged internet search has at the end of the day been paid with excellent tips to talk about with my contacts. I 'd express that we visitors actually are definitely endowed to dwell in a fine site with so many marvellous professionals with interesting guidelines. I feel truly happy to have used your entire webpages and look forward to some more fabulous times reading here. Thanks a lot once again for everything.
moncler jackets http://www.monclerjackets.us.org
Reply off white outlet
10:18 PM on June 18, 2022 
I simply wanted to thank you very much again. I'm not certain the things that I could possibly have worked on in the absence of the actual ideas shared by you regarding such problem. This was a real frightening setting for me, nevertheless looking at your expert form you dealt with that took me to weep for fulfillment. I will be thankful for this support and thus hope that you comprehend what an amazing job that you are carrying out educating men and women by way of a blog. I am certain you haven't come across any of us.
off white outlet https://www.offwhitesoutlet.com
Reply yeezys
4:00 PM on June 27, 2022 
I happen to be writing to let you know what a extraordinary encounter my wife's daughter enjoyed reading through your webblog. She realized so many issues, most notably what it is like to have a marvelous helping style to make a number of people without difficulty have an understanding of certain specialized subject areas. You really exceeded our own desires. Thank you for producing the insightful, safe, explanatory not to mention fun tips about that topic to Julie.
yeezys http://www.supplyyeezys.com
Reply yeezy 380
4:00 PM on June 27, 2022 
My wife and i felt really contented when Emmanuel could carry out his basic research because of the precious recommendations he discovered out of the blog. It is now and again perplexing just to possibly be giving freely helpful hints which other people might have been making money from. We know we've got the website owner to thank for that. The explanations you've made, the simple site menu, the friendships you can help to engender - it is many great, and it is assisting our son and our family reason why the content is amusing, and that is rather fundamental. Many thanks for the whole thing!
yeezy 380 http://www.yeezyboost380.us.com
Reply jordan sneakers
4:01 PM on June 27, 2022 
I must point out my appreciation for your generosity for men and women that absolutely need guidance on this particular concern. Your special dedication to passing the message across appeared to be quite productive and have usually helped individuals just like me to attain their goals. Your personal warm and helpful recommendations signifies a lot to me and far more to my fellow workers. Best wishes; from everyone of us.
jordan sneakers http://www.jordanssneakers.us.com
Reply jordan shoes
4:02 PM on June 27, 2022 
I and my pals ended up going through the great strategies from the website and so at once I got an awful feeling I never thanked the site owner for them. All of the young boys are actually absolutely thrilled to learn them and have pretty much been tapping into these things. Many thanks for indeed being considerably accommodating and also for picking varieties of remarkable resources most people are really wanting to be informed on. My sincere regret for not expressing gratitude to you sooner.
jordan shoes http://www.jordan12.us.com
Reply curry shoes
4:02 PM on June 27, 2022 
I'm writing to make you be aware of what a wonderful encounter my friend's daughter obtained reading through your web site. She came to understand lots of details, with the inclusion of how it is like to have a great helping mindset to make the others really easily know precisely specified specialized subject matter. You actually surpassed her desires. Thanks for imparting such important, safe, informative not to mention unique guidance on the topic to Julie.
curry shoes http://www.curry-7.com
Reply nike sb dunks
4:04 PM on June 27, 2022 
I as well as my pals appeared to be analyzing the excellent secrets and techniques located on your web site and all of the sudden I got an awful feeling I never thanked the site owner for those tips. All of the women came for this reason very interested to read them and have in effect clearly been loving those things. Appreciation for indeed being very helpful as well as for deciding upon this kind of nice information most people are really wanting to be aware of. My personal sincere apologies for not saying thanks to sooner.
nike sb dunks http://www.sbdunk.us
Reply kd 13
1:20 AM on June 29, 2022 
Thank you a lot for giving everyone an exceptionally brilliant possiblity to discover important secrets from this website. It's always so pleasing and as well , full of a great time for me and my office colleagues to visit your web site at minimum three times weekly to study the newest issues you have got. And definitely, we're always happy with the beautiful concepts you serve. Some two tips in this post are particularly the simplest we have all had.
kd 13 http://www.kd13shoes.us
Reply nike off white
1:21 AM on June 29, 2022 
I want to show my appreciation for your kind-heartedness supporting persons that really need help on the issue. Your personal dedication to getting the message across ended up being exceptionally beneficial and has truly empowered ladies much like me to realize their ambitions. This insightful publication can mean a lot a person like me and a whole lot more to my peers. Thanks a ton; from each one of us.
nike off white http://www.offwhiteshoes.us.com
Reply jordan 11
1:21 AM on June 29, 2022 
I really wanted to compose a remark to be able to say thanks to you for these fabulous tips and hints you are posting at this site. My extended internet search has now been honored with wonderful facts to exchange with my companions. I 'd assert that most of us website visitors are unquestionably endowed to dwell in a superb site with very many brilliant professionals with valuable solutions. I feel truly fortunate to have come across the web page and look forward to really more awesome times reading here. Thanks once more for a lot of things.
jordan 11 http://www.jordan11retro.us.com
Reply supreme clothing
1:21 AM on June 29, 2022 
I'm also commenting to make you be aware of what a brilliant encounter my friend's princess developed studying yuor web blog. She even learned a lot of issues, which included what it is like to have an incredible coaching mood to have many people without difficulty know precisely specified very confusing issues. You actually surpassed people's expected results. Thanks for rendering the insightful, dependable, informative and even easy tips about your topic to Julie.
supreme clothing http://www.supremeclothingstore.com
Reply off white clothing
1:21 AM on June 29, 2022 
I simply wanted to construct a comment to say thanks to you for those nice solutions you are posting on this site. My rather long internet lookup has finally been compensated with high-quality ideas to go over with my co-workers. I 'd mention that we site visitors are truly blessed to exist in a remarkable network with so many special people with valuable methods. I feel rather happy to have come across your site and look forward to some more exciting times reading here. Thank you again for everything.
off white clothing http://www.off--white.us.com