The Central Economic-Administrative Tribunal (TEAC), in its decision of 25/03/2026 (RG 5861/2025), issued in an extraordinary appeal for unification of criterion, holds that a tax notification made at the taxpayer’s tax domicile, despite the prior designation of a representative with an address for notifications, is not necessarily invalid in a procedure initiated ex officio. If the notification achieves its purpose (that the act reaches the taxpayer’s actual knowledge in time to react), it is fully effective; the criterion yields if the taxpayer shows that the act did not reach them in time to challenge it. The dies a quo of the time limit to appeal runs from the date of the notification, not from the material handover by the third party. The TEAC thus qualifies the Supreme Court judgment of 01/07/2025 (appeal 3905/2023) under the purpose-achieved rule, consistently with the judgment of 07/10/2015 (appeal 680/2014).
The practical consequence, for defensive purposes, matters especially in inspection or management procedures initiated ex officio. The designation of a representative does not shield the taxpayer against the time limit running silently if the notification fulfils its communicative function. It is advisable to keep track of the communications received at the tax domicile and at the representative’s address, to set up an internal reception protocol that minimises the risk of a notification being left unprocessed and, where appropriate, to make the designation of the representative as clear as possible so that the acting body takes it into account. Whether the time limit to appeal is preserved in full or runs out without reaction may depend, in practice, on that internal protocol.
https://spanishtaxjournal.com/en/2026/03-25/nota-teac-notification-purpose-achieved/