The Constitutional Chamber of the Supreme Court of Justice, through resolution issued on January 11th, 2019 in the unconstitutionality process identified with reference 156-2015, admitted an action challenging the constitutionality of the following provisions: (i) Article 5 of the Law based on the alleged violation of the legal certainty principle; (ii) Article 4 of the Law based on the apparent transgression of the fairness and equity principle; (iii) Articles 2 and 3 of the Law on the grounds of the alleged violation of principle of general tax revenue; and (iv) Articles 4 and 5 of the Law on the grounds of the alleged violation of the principle of legality in tax matters.
Although the action was admitted, the Constitutional Chamber decided not to suspend the effects of the Law. Consequently, large taxpayers must comply with the Law until indicated otherwise by the Constitutional Chamber.
The resolution on January 11th, 2019 in the unconstitutionality process 156-2015 may be consulted by clicking here. (available only in Spanish).