Is it advisable to bring an administrative appeal or better appeal directly to the Administrative Economic Court?

The processing of a reversal of appeal, albeit slow, is much faster than via the economic administrative process, which means that in certain cases, a reversal of appeal may be advisable to do in advance.

However, it cannot be denied that, except in cases of error or omission in manifest, are rare occasions in which an administrative body agrees to rectify its own administrative acts.

Therefore bringing an administrative appeal is advisable when the reasons given by the taxpayer are absolutely clear and leave no doubt about the irregularity of the act issued by the Administration.

By contrast, in cases where the chances of getting a favourable decision at the administrative level are less likely, it is advisable to forego the appeal.

In any case, the game of the silent administration (see section 4.8) subtracts importance to the issue.