Supreme Court dismissed VAT late fees based on tax control results, ruling control findings are declaratory not constitutive.

The Supreme Court dismissed the taxpayer's extraordinary revision against the tax authority's decision to calculate late fees from the date of the tax control result. The court held that the Tax Control Act only grants the control result declaratory effects regarding the tax debt itself, not the legal consequences like late fees. Consequently, late fees must be calculated from the original date the tax obligation arose, not from the date the control confirmed the higher amount.