When may tax assessments be notified collectively?

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As a general rule, tax assessments must be notified to the taxpayer under the applicable tax-notification rules (Article 102(1), General Tax Law 58/2003, or LGT).

For taxes collected periodically by receipt, once the assessment corresponding to the initial entry in the relevant register, roll or list has been notified, subsequent assessments may be notified collectively by public notices stating that they are being issued (Article 102(3) LGT). This is a specific exception; it does not mean that every recurring tax can be notified collectively without first notifying the initial assessment.

Collective notification is not conditional on each later assessment being identical to the previous one. Article 102(3) LGT separately requires individual notice of an increase in the tax base over the amount resulting from the taxpayer’s returns, with the specific facts and additional elements supporting the increase. The exception is a change resulting from a general revaluation authorised by law.

Periodic local taxes such as the property tax (IBI) and motor vehicle tax (IVTM) are common examples, but the statutory conditions must be checked for the particular tax and assessment. There is no general rule that collective notice is lawful only when the taxable event or the amount remains unchanged over time.

For periodic receipt taxes, the additional provision 14 of the Local Finance Law (Legislative Royal Decree 2/2004) also provides that individual notice is not required for generally applicable changes to tax elements made through the relevant local tax ordinances, subject to the cases in Article 102(3) LGT.

Official sources: General Tax Law 58/2003 (LGT), Article 102, https://www.boe.es/buscar/act.php?id=BOE-A-2003-23186 ; Local Finance Law (Legislative Royal Decree 2/2004), additional provision 14, https://www.boe.es/buscar/act.php?id=BOE-A-2004-4214