In general, when an administrative act does not appeal within that purpose prescribed by law, they become final. Thus, once this period has elapsed, the action of the taxpayer declines for appeal.
However, there are exceptional reasons that allow the taxpayer to appeal the administrative act, even after the deadline for submission of regular resources (economic and administrative claim replacement) has elapsed. This resource, which can only be lodged where certain exceptional circumstances, is known for special review.
The grounds on which to base this resource are specified by law and are as follows:
a) In issuing the administrative act, it had made a manifest error of fact resulting from the actual documents contained in the file.
b) Documents in which appear essential value for the resolution of the claim, ignored when issuing this or that, at the time, were impossible contribution to the file.
c) That resolution has essentially influenced false documents or testimonies declared by final judicial decision.
d) That resolution had been issued as a result of prevarication, bribery, violence or other fraudulent scheme, and had thus declared under court order.
The law provides for the following deadlines for filing an extraordinary appeal for review:
1. In the first case, within four years from the day following the notification of the act or decision which is contested.
2. In all other cases, within three months from that had occurred the foreseen circumstances (discovery of documents or final judgment).
In any case, it shall have jurisdiction to resolve the TEAC and against the decision handed down, may be brought an administrative appeal before the National Court.