The Law of Partial Reform of the Tax Code expressly provides that the new rules will apply to tax offenses committed prior to its entry into force, provided that their application is more favourable to the offender and the sanction imposed has not acquired firmness.
In other words, the new rules will apply retroactively (and only when it is more favourable to the taxpayer), the disciplinary proceedings opened, either for having put its processing on hold its processing or for appealing sanctions before the administrative or ordinary courts administrative.
In this regard, it should be noted that as a result of the expected modification of the sanctions regime -the result of the mentioned Law Reform of the Directorate General of the Tax Agency, through an internal instruction of December 14, 1994, ordered the inspection bodies the suspension of the disciplinary proceedings pending resolution.
In any case, the review of the sanctions that have not become final will be made by the body that is hearing the corresponding claim.
Depending on the instance in which it is found, it can be integrated within the administration itself or directly with the Ordinary Courts of Justice.