The Council of State clarified the legal deadlines for challenging administrative acts issued by the National Tax and Customs Authority when notice is served electronically.
The ruling provides a technical analysis of the correct method for calculating statutory time limits to determine the deadline for filing a motion for reconsideration (recurso de reconsideración) against a sanctioning resolution (resolución sanción) notified electronically pursuant to Article 566-1 of the Tax Code (Estatuto Tributario E.T.). The Fourth Chamber of the Council of State […]