Coordination and controversy between public bodies responsible for resolving tax disputes in matters of local taxation:: Comptroller General of the Republic, Courts of Appeals, Supreme Court, and Constitutional Court.

Abstract

This paper exposes and analyses the different legal perspectives of the decisions of the ordinary jurisdiction (Courts of Appeals and Supreme Court of Justice), the decisions of the public administration (Comptroller General of the Republic) and the constitutional jurisdiction (Constitutional Court and Supreme Court) regarding the application of the (Municipal patents) to passive investment companies, highlighting the elements of disagreement between the different administrative and judicial bodies competent for their solution, as the result that is crystallized in the current state of the matter. The author emphasizes how the decisions of the public bodies involved have become uniform, notwithstanding that the law seems to allow different possible solutions to the same type of cases.