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Spain: Lifting of non-tax procedural and administrative deadlines under “state of emergency” (COVID-19)

Spain: Lifting of deadlines under “state of emergency”

A resolution, published in the official gazette on 23 May 2020, reflects an end of the “state of emergency” declared under Royal Decree 463/2020 of 14 March 2020 and offered in response to the coronavirus (COVID-19) pandemic.

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The May 2020 resolution reflects an agreement reached by the Lower House of the Spanish Parliament on the state of emergency provided for by Royal Decree 463/2020. Accordingly, given there are no further extensions, the period of the state of emergency begins 14 March 2020 and runs through 6 June 2020.

The resolution reflects the lifting of the suspension of procedural and administrative deadlines; these measures, however, generally do not concern taxation. Instead, refer to the discussion below under “Tax-related deadlines”.

  • The suspension of procedural deadlines is “lifted” as from 4 June 2020 (the date when a provision of Royal Decree 463/2020 is repealed). Accordingly, any periods and deadlines under procedural laws that may have been suspended during the state of emergency will be calculated “from scratch,” and the period will start running as of 4 June 2020.
  • Concerning administrative deadlines, the relevant calculations resumed as of 1 June 2020 (the date when another provision of Royal Decree 463/2020 is repealed). Similarly, regarding the periods suspended or tolled, the calculation will resume for the period outstanding, or will start from scratch.
  • The suspension of limitation periods and expiration dates for rights and actions is lifted as from 4 June 2020.

Tax-related deadlines

Regarding tax-related matters, Royal Decree 465/2020 of 17 March 2020 expressly provided that the suspension of the administrative deadlines, periods, and procedures (as described above) did not apply with regard to tax-related deadlines. Thus, the suspension of tax-related deadlines and periods was subject to its own specific rules as provided by Royal Decree-Law 8/2020 of 17 March 2020, and Royal Decree-Law 11/2020 of 31 March 2020 (and as subsequently extended under Royal Decree-Law 15/2020, of 21 April 2020).

In general, the tax-related deadlines were extended to 30 May 2020.

Again, the measures to lift the suspension of deadlines (described above) do not affect the tax-related deadlines during the state of emergency.


Read a June 2020 report [PDF 195 KB] prepared by the KPMG member firm in Spain

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