Derivation of tax liability

Interim relief and seizure

Persons liable for a tax debt

In addition to the taxpayers who are the main debtors, the tax law may declare other persons or entities liable for a tax debt, to whom the law extends liability for payment of the tax, under certain circumstances.

The extension of the tax liability to persons who have not carried out the taxable event is a measure aimed at facilitating and securing tax collection, by ensuring the collection of taxes and also as a mechanism to avoid evasive or fraudulent conduct.

The particularity of this procedure lies in the fact that the derivation of the collection action, and therefore the commencement of the collection proceedings against the liable party, is subject to the existence of an administrative act declaring liability.

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Interim relief

The purpose of the interim relief set out in the Taxation Act (“LGT”), is to ensure the collection of debts and tax penalties, becoming one of the most effective ways to try to stop the increase of the amounts defrauded on the one hand and to achieve their collection on the other. However, in practice, a difficulty arises with regard to the inclusion of penalties within the scope of interim relief, due to the possibility of automatic staying of its enforcement, without the need to provide guarantees, due to the timely filing of a tax complaint or appeal, a stay that will be maintained until the relief becomes final in the administrative track.


As a result of the above, the tax authorities may seize assets. If you are involved in this process, please contact us. We can help you

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