It is a common mistake, but not illogical for the layman, to think that the initiation of enforced recovery can be appealed with underlying reason. This is to disregard the nature of the enforcement procedure, as we have already noted, it is merely a procedure for the collection of a debt, once the voluntary payment period has run out.
Thus, if a taxpayer receives a settlement from the Administration, for whatsoever reasons considered not in accordance with law, they must appeal the settlement themselves, in due time and form to the appropriate body, within the terms set out in chapter 4 of this manual. It is in this procedural stage where they should appeal the underlying reasons of form or substance that substantiates their right.
Now, if the taxpayer in question appeals or doesn’t appeal the settlement it does not guarantee the tax liability on the terms provided in section 4.9, the collection procedure continues its course. Consequently, the next step is that the enforced recovery starts automatically. Once this has begun, the taxpayer may no longer appeal any underlying reason, but solely the reasons stated in the previous section.