After the publication of Sentence No. 147/2022 of November 29, the Constitutional Court opens the way to challenge those administrative notifications that, despite having been notified electronically because it is mandatory, the interested party can prove that they did not agree to the notification nor was he aware of its existence.
In these cases, if the Tax Agency is aware that the interested party has not been aware of the notification in question, it is obliged to resort to alternative means of communication in order to safeguard the right to effective judicial protection of the interested party.
#Constitutional Court, #notifications, #fiscal, #ProlawIberia.