De nuevo sobre la suspensión de la ejecutividad del acto administrativo de naturaleza tributaria

Laburpena

The institute for the suspension of the enforceability of administrative acts of a tax nature has been subject to some changes caused by Law 11/2021, of July 9, on prevention measures and the fight against tax fraud, with a clear purpose of protecting the tax credit. We will stop at these modifications because, sometimes, they try to face the most guaranteeing jurisprudence in favor of the taxpayers. But before we analyze other dilemmas that, not because they are old, are very topical, since the legal regime of the suspension deserves a regulatory review that seeks to achieve a more uniform regulation both in the administrative and jurisdictional channels, as well as closer to the most guaranteeing positions with the principle of precautionary justice. The development regulations of the LGT have recently been modified by Royal Decree 249/2023, of April 4th, which we also collect in this work.