Motion for reversal of Audit settlements.

General Data


Motion for reversal of Audit settlements.

Type of procedure

Tax Procedure




Rulings of the Tax Administration related to economic-administrative appeal can be subject to optional prior appeal for reversal. The authority that issued the ruling will be competent to deal with and resolve the appeal against said ruling.
If the interested party lodges an appeal for reversal, they cannot file an economic-administrative appeal until the appeal has been expressly resolved or until it can be considered dismissed due to administrative silence.

Responsible body

Tax Agency

General information on the procedure

Start method

Interested party

Applicant: Company - Citizen

Place of presentation

  • Online

  • AEAT offices

  • Post Office

  • Other places authorised under article 16 of Law 39/2015


Appeal lodging document

Procedure/service stages

  • Initiation: Via appeal lodgement document, one month from the day after notification of the challenged ruling has been made or the day after that on which the procedure is deemed dismissed due to expiration of the deadline without an express resolution having been issued.
    When lodging the appeal, the interested party will certify that no appeal has been filed against the same ruling via an economic-administrative procedure. The appeal document shall include the arguments put forward by the interested party in relation to facts and legal grounds. The appeal will be accompanied by those documents that form the basis for the appeal being made.
    Lodging the appeal will not prevent enforcement of the challenged ruling. However, at the request of the interested party, enforcement of the challenged ruling will be suspended pursuant to the terms set out in the regulations for this procedure.

  • Procedure: The reversal submits all questions that arise during the procedure to hearing by the authority competent to issue a resolution, regardless of whether or not they have been included in the appeal; under no circumstances may the initial situation of the applicant be worsened.

  • Completion: Via resolution that upholds or dismisses the appeal.

Resolution deadline

1 Months

Resolution body

Tax Agency


Economic-administrative appeal: Application period: One month from the day following notification of the resolution of the motion for reversal or from the day following that on which it is deemed to be dismissed. Appeals should be addressed to the administrative body that dictated the contested decision.

Information concerning electronic procedure

Identification system

Electronic DNI (Spanish National ID), Electronic certificate, Clave PIN

Interactivity level

Level 4: Electronic processing


Normativa Básica

Ley 58/2003, de 17 de diciembre, General Tributaria. Artículos 213 a 215 y 222 a 225. (BOE 18-diciembre-2003)

Real Decreto 520/2005, de 13 de mayo, por el que se aprueba el Reglamento general de desarrollo de la Ley 58/2003, de 17 de diciembre, General Tributaria, en materia de revisión en vía administrativa. Artículos 1 a 3, 21 a 27. (BOE 27-mayo-2005)