La controvertida doctrina del «doble tiro» y su reciente concreción jurisprudencial: STS 1201/2025, de 29 de septiembre, rec. núm. 4123/2023

Abstract

The partial acceptance of claims or appeals against tax assessments sparked considerable debate regarding the scope of such rulings, the extent to which they allowed the tax authorities to correct their decisions, and the number of times such corrections could be made.

Given certain shifts in case law on these issues, the recent Supreme Court ruling of September 29, 2025 (appeal no. 4123/2023) sheds much-needed light on the matter and clarifies almost all of the controversial questions raised, although some may remain unresolved.

The partial acceptance of claims or appeals against tax assessments sparked considerable debate regarding the scope of such rulings, the extent to which they allowed the tax authorities to correct their decisions, and the number of times such corrections could be made.

Given certain shifts in case law on these issues, the recent Supreme Court ruling of September 29, 2025 (appeal no. 4123/2023) sheds much-needed light on the matter and clarifies almost all of the controversial questions raised, although some may remain unresolved.