As discussed in Chapter 1, the Administration has the power to clear settlements, provisional or final. But the fact that it is final does not mean in any way that such settlements are firm.
Therefore, whether provisional or final, the taxpayer who has received notice of the withdrawn settlement by the Administration has the right to appeal against it.
The administration is required to notify the taxpayer, at the time of notifying the settlement, the resources that can be brought against it, indicating the deadlines and bodies to which it must be submitted (see section 6.2).
In general, when a taxpayer receives a settlement, they can choose to appeal before the same court that issued the act or, alternatively, to appeal directly to the Administrative-Economic (economic-administrative appeal) courts.
These resources are discussed in sections 4.2 and 4.3.
In addition to these resources, which may be called "ordinary", the Law provides the figure of the extraordinary review, which comes in the exceptional circumstances which are discussed in section 4.6.
The resources cited share a common characteristic: in all cases it is the "administrative" resources to be resolved by bodies of the administration itself.
Subsequently, once the administrative review has been exhausted, taxpayers can go to the courts by the so-called administrative appeal which may be brought before the High Courts of Justice of the Autonomous Community or before the National High Court. This resource is discussed in section 4.10.