Resolución convencional de controversias tributarias en el marco de la experiencia del Derecho comparado

Abstract

Our intention in the pages that continue is explain, in a systematic way, the bases on which settled the relations between the taxpayer and the Tax Administration in the compared law, now that an analysis on the diverse alternative techniques of resolution of tax disputes would lack sense if there was not born in mind the development that have had in those laws where many of them started his wanderings.

The development of mechanisms, formulas or alternative instruments of resolution of tax disputes answers to a tax reform movement extended to western tax legal systems worried for obtaining the voluntary participation of the taxpayers with the Administration, with the intention of achieving an approximation of positions, mutual understanding, in the resolution of tax disputes.