Nulidad de las liquidaciones de plusvalía impugnadas antes de dictarse la STC 182/2021: STS de 28 de marzo de 2023, rec. núm. 4254/2021
DOI:
https://doi.org/10.48297/rtt.v3i142.2392Keywords:
Capital gains tax, unconstitutionality, nullity, res judicata, limitation of effects of judgments, «consolidated situations»Abstract
The various rulings of the Constitutional Court that have adjudicated on the Urban Land Appreciation Tax have generated numerous conflicts of interpretation and application. This is why the verdict contained in this ruling, which declares the invalidity of all assessments that had been contested in cases where the situation was not «consolidated,» is of interest. In other words, whenever it was not a matter of situation definitively decided by a judgment with the authority of res judicata, or by final administrative resolutions.
