a) Filing a special tax-lawsuit at the Costa Rican Court of Claims as a legal remedy against the Fiscal Administrative Court's decision

In terms of decision, the Fiscal Administrative Court issues two rulings: either it affirms the appellant's motion; thus, revoking the Resolución Determinativa, or it denies the motion; which provides the legal grounds for bringing an action. The appeal then turns into a special lawsuit called special tax contentious-administrative process (proceso contencioso administrativo especial tributario) and it must be filed at the Costa Rican Court of Claims in the first intance within 30 days after the Fiscal Court's decision has been served to the party. The appeal is very simple in terms of content. This is because in another stage of the process, the appellant is summoned to state all his arguments in depth.

b) Defense from lawsuits brought by the State against the taxpayer

Upon revocation or anullment of the Notice of Charges (Traslado de Cargos) or the Resolución Determinativa by the Fiscal Administrative Court, the State may bring an action against the taxpayer. The objective is to claim for a reversal of the administrative decision in judicial grounds; therefore, it is also considered an appeal. As in the previous case, the lawsuit must be filed at the Court of Claims within 30 days of the Fiscal Court's service. This special action is technically called proceso contencioso administrativo de lesividad, and it is the taxpayer's responsibility to defend him/herself against the State's lawsuit.

c) Furnish of the evidence

In both of the special judicial actions mentioned before, the parties must attend a hearing in which the evidence is furnished. The procedure must follow the guidelines set in the Código de Normas y Procedimientos Tributarios, in the Ley Reguladora de la Jurisdicción Contencioso Administrativa and also the procedures of the Código Procesal Civil (all of them refering to Tax legislation and procedures Code, the jurisdiction under the administrative law legislation and the Civil Procedures Code).

d) Appeal of the lower court's decision

In the judicial action of the State against the taxpayer (proceso contencioso administrativo de lesividad), if the Court of Claims of the first instance rules against the taxpayer, he/she must motion to the Court of Appeals.

e) Appeal to the Court of last resort

Decisions of the Court of Appeals in the both processes described above may be subject to an appeal of last resort. This remedy may be used by the defendant provided the estimation of the lawsuit exceeds a certain amount of money and that there are enough merits to prove an error of law or breach of some procedural right. The appeal is filed before the First Court of Last Resort of the Supreme Court.