The incidence of the "Alpha Shipping S. A." ruling on the local determinative processes

Abstract

The institution of prescription in tax matters and the power of local jurisdictions to regulate it normatively has always been a debated topic both in relation to the actions and powers of local tax authorities to determine and demand taxes, and to apply and enforce  sanctions.
Doctrines with different perspectives are presented on this topic, upon which the Supreme Court has issued various rulings that shed light on the matter.
In this article, we will recount both the main aspects of the aforementioned doctrinal positions and the jurisprudence issued by our Supreme Court with some mentions of local rulings,  culminating in the analysis of "Alpha Shipping," which, although it seems to put an end to the discussion, also raises multiple questions that will be analyzed here.