The formulation of the full assessment principle by the courts and its pending regulatory developmen

Abstract

For more than fifteen years now, case law has been refining the content of what has been called the principle of full assessment. This paper reviews the most recent resolutions in this regard in their three aspects: «double- sided» assessments (section 3); those related to the effects of remote periods on present assessments (section 4); and those that are based on the unity of the tax system (section 5). It is preceded by a reference to the principles on which it is built (section 2) and closes with a final consideration of what should be its always postponed normative reception (section 6)