Can the European sentence of the 720 model benefit Spanish defenders, such as the Pujol?

  • The tax law states that the TEDH case has an effect on the criminal proceedings by the tax authorities.

All sentences and more Europeans have o deberían tener application in the procedures in which they are directed as semantics, to strictly comply with the principle of equality before the law. The problem is that these cases are completely irrelevant and that the resolutions need to be studied in detail in order to determine exactly their application, administrative and criminal ambitions and apply retroactive form or not.

If there are any conclusions to be drawn, we would like to send a letter to the Court of Justice of the European Union on the 720 model without having to worry about it. Ese fello, who declared that the española española which obliges tax residents in Spain to declare your property or property located abroad vulnera el derecho comunitario, porque impone restrictions on the free circulation of capital “disproportionate & rdquor; which is contrary to the law of the EU, has been rapidly exacerbated by various defenses, such as the Pujol to ensure that it supports a review of the procedures that are open to the Tributary Agency.

The defense of the Catalan president ensures that in the follow-up to the Tributary Agency is “determinant”

From the defense of the Pujol family, owning the lawyer Cristóbal Martell, it is clear that this diary the case is “indifferent” to the criminal proceedings which is seen against it in the National Audience, but for those who have abated the Spanish fish with millions of millionaires “is decisive”, because it implies that the multitudes can not impress.

In the case of the rey emeritus, which only has fiscal diligence that it has announced that it will be filed, according to the facts of Hacienda consulted, the case of TJUE will not affect, moreover the imprintability in the case in which it is hallaran new assets in the foreign exchange, since no one has been paid by the Tributary Agency. Juan Carlos I presented fiscal regulations for more than four million euros, which were revised by the Tributary Agency to approve the requirements for veracity and spontaneity.

Joint meetings

As regards the Anti-Corruption Taxation, in relation to this procedure and the large-scale fraudulent relations that increase the level of tax offenses, it is ensured that the European resolution will be studied with detention both by the public ministry as by the Agencia Tributaria at joint meetings to determine whether their alcance extends to the administrative life or the penalty or only some of them or none, and also whether they have a retroactive character or not.

In any case, it is clearly improbable that criminal offenses in Spain are affected. Since the public ministry is also signaling that in principle in the specific case of the Pujol its obligation to declare its assets in the foreign country determined by the tax evasion, which has direct recourse to those declaring in their respective IRPF declarations, no for no haber presented the document 720. Here the European case does not intervene in the criminal case.

To the defrauding peoples

For its part, for the President of the Association of Inspectors of Hacienda, Ransés Pérez Boga, and in the hope of analyzing the content of the sentence to determine its effects, the decision of the TJUE will favor “to the defrauding peoples, whose sons, in addition to defrauding, han occulto the diner fuera “ of our country.

The inspectors of Hacienda lamentan that whoever benefits more than whoever admits the fraud

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The ‘quid’ of the question, according to this expert, finds himself in the place that tends to the affected to advertise the revolution of the multitudes. For the spokesman for the Technical Union of the Ministry of Education (Gestha), Carlos Cruzado, in principle this period is a series of four years. In other words, the resolution is favorable to all those who have had fiscal consequences for the application of the Model 720 in the last four years.

Cruzado clarified, in all cases, that the European Court of Justice’s resolution, does not plant the elimination of the contributing model, without the obligation of some of its consequences. “Ahora, debe mantenerse de modelar de declaration modifying las sanctionen consezancas para acomodarlo a la sentencia”, explica a este diario. For this, the details that the sanctions that can be advertised, in principle and in the hope of a more detailed study of the resolution, will be the ones that will not hurt companies “.

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