The European Commission has recently opened an infringement procedure against Spain, challenging certain points of the Spanish legislation on the obligation to declare assets and rights located abroad through form 720.
The procedure will presumably make it necessary for the Spanish legislator to reconsider the consequences deriving from the non-submission of the form 720, and it will probably open the gate to an extraordinary regularisation procedure for all those taxpayers that have not filed the return within the statutory deadline, with less severe penalties and the possibility to allege the statute of limitations.
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