La expansión del principio de regularización íntegra en materia tributaria

Abstract

This paper analyzes the content, characteristics and different manifestations of the principle of full regularization in tax matters. After exposing the cases of jurisprudential application of the principle, its basis and extension in the different tax procedures, it analyzes its application  in the so-called «double-sided» regularizations, in which the liquidation of a debt entails the recognition of the right to the refund of undue income. It also addresses the effects of the principle in the sanctioning sphere, formulating different proposals for its  necessary reception in the LGT.