The Reference Value in the Face of Contradictory Expert Evidence: Administrative Reasoning and the Limits of the Model

Abstract

This article examines the reference value in Spanish property taxation from the perspective of its application when the taxpayer submits contradictory expert evidence. Drawing on recent Constitutional Court case law, it argues that the model’s validity does not depend solely on its abstract design, but on the effective possibility of evidentiary contradiction in the specific case.
The paper analyses the current statutory and case-law framework, identifies the existing asymmetry in the duty to state reasons when a well-founded expert report is submitted, and maintains that administrative reasoning constitutes the main operative limit of the model. It concludes by proposing a normative clarification aimed at ensuring an individualized and reviewable administrative response.