Conclusions brief before the National Court

The conclusions are the final photograph of a dispute: what each party maintains when there is nothing left to provide. This brief took that photograph.

The procedure

• Order of 15 December 2022: requirement of written conclusions within ten days.
• Brief submitted on 10 January 2023 — in time, like every step of this party in the procedure (A.60, A.61).

The opposing position, cited and answered

The Illustrious Representative of the State Legal Service considers in summary that the nullity does not lie since the communication of change of address we allege is not on record
— Conclusions brief, proceedings 60/2022, summary of the State's reply

Against this, the conclusions order the material the reply had gone around (A.62): the calendar of the limitation (A.40), the costs expert report without a counter-report (A.49), the address on record in the tax archives (A.65) and the cross-border enforcement consummated on all of it (A.41).

The claim

Granting judgment, annulment of the challenged act and restoration of the economic balance of the administered party — the legal formula for returning what was expropriated to the person whom the Administration itself valued as an investor of 1,778,000 euros (A.10) before assessing him as a debtor.

How to verify it

Read the conclusions of both parties in parallel (this one and A.64). Note which documents each cites and how many of them the other challenges. The entire dispute fits in that two-column table.