This last phase concludes the informal stage and takes place when the taxpayer or debtor proceeds to pay the tax debt before an office receiving national funds or before the banks authorized by the Ministry of Finance by means of a contract signed for such purpose.
The next stage is the contentious stage, which contemplates a series of administrative and jurisdictional appeals, in the event that the taxpayer does not agree to pay the tax due to disagreement with the liquidation established by the administration. It is established when, how and where to file the appeals.
Regarding the hierarchical appeal, it consists of an administrative appeal, where the taxpayer, within certain business days following the notification of the administrative act being challenged, expresses in writing the reasons of fact and law that support the challenge, before the body that issued the act or through any tax administrative office, accompanied by the challenged act or being sufficiently identified.
The following is the appeal for review, this appeal remedies defects incurred in the processing of the hierarchical appeal, for this reason the addressee of this act is the same authority that heard the hierarchical appeal against a final administrative act.
The appeal for review must be filed within the peremptory time periods following the date of the aforementioned judgment or administrative act, or after the existence of the evidence essential for the resolution of the matter has become known, in view of the facts known by a final and definitive judicial judgment.