The imposition of penalties ex articles 194.1 and 195.1 LGT is compatible with the derivation of joint liability for participation in the commission of the infringement of article 201.3 LGT

Abstract

This paper consists in a comment about the Supreme Court Judgement 1177/2020, of 17 September referring to the study of the triple identity that presupposes the infringement of the material aspect of the non bis in idem principie protected by Article 25.1 of the Spanish Constitution in the context of a sanctioning tax procedure, as well as the possibility that a double fiscal repression contravenes the principie of inherence enshrined in Article 180.1 of Law 58/2003 of 17 December, Tax General.In these pages we will analyse and make notes on the most recent jurisprudential criteria that the Court has established in relation to the ne bis in idem principie in the field of punitive tax law.