The Role of INEN in the Administrative Process for Regulatory Infringement

INEN-regulatory-miguel-maigualema-corralrosales

The Ecuadorian Standardization Service (INEN) is part of the Ecuadorian Quality System and plays an important role in regulation, standardization and metrology. It also participates in administrative proceedings carried out by the Sub-Secretary of Quality for infringements.

INEN is responsible for conducting inspections to verify compliance with technical standards before and during an administrative proceeding. The first inspection, which can be ex officio or by complaint, is intended to determine the conformity or not of a product with the corresponding technical standards. If the result is “non-compliant”, the Sub-Secretary of Quality will bring a sanctioning administrative proceeding.

As an example, in the controls carried out in compliance with the Ecuadorian Technical Regulation RTE INEN 284 “Quantity of product in prepackaged / pre-encased”, a term of 30 days is granted for the company to amend or justify the nonconformities detected in the first inspection. At the end of the 30-day term, INEN carries out the second technical inspection and if the non-conformity still exists, the Sub-Secretary of Quality can apply the sanctions provided in the Law of the Ecuadorian Quality System.

The 30-day term granted to execute corrective actions is sufficient in the case of national products, but it is not sufficient for foreign products. This situation has caused several companies to be sanctioned without considering the time, costs, and other eventualities that importing products entails.

When applying sanctions, the Sub-Secretary of Quality takes into account the reoccurrence of such nonconformities, so it is very important that companies make the necessary changes and file the required technical justifications, as well as their legal arguments before the second verification.

As derived from the preceding paragraphs, the function of INEN is to ensure compliance with mandatory technical standards whose main objective is to protect consumers.

INEN is part of several international organizations and applies international standards or parameters in the controls it performs; an aspect that has contributed to the acquisition of new skills, the application of new guidelines, and the accumulation of experience in the execution of its work. This office has put emphasis on the above-mentioned quality controls, especially regarding the net content of a product. To do so, it has adopted a monthly schedule to perform random inspections and verifications for each type of product.

Miguel Maigualema
Asociado en CorralRosales
miguel@corralrosales.com

Ecuadorian IP Office Overturns Problematic Lower Instance Decision on Recognition of English Language Terms

animal-planet-propiedad-intelectual-idioma-ian-wall

The territory of the Republic of Ecuador is predominantly Spanish speaking. Amerindian languages are also widely spoken, particularly provincially, but their use is gradually diminishing. Despite the dominance of Spanish in Ecuador, the English language is everywhere, and its influence could be said to be growing. This poses certain interesting questions from a trademark law perspective, since the general approach of the Ecuadorian IP Office is to consider terms in foreign languages as “fantasy terms”. That is, foreign language terms will not be considered as being understood by the general public, except in the case of the most commonly known words.

The stated position is more complex in practice when one considers that due to the continued encroachment of the English language throughout the American Hispanic region, generally accepted as even more marked than in the case of the Iberian-Hispanic world, the list of well-known English words is growing and therefore not a fixed concept. In addition, what is or is not a “well-known English word” is largely subjective, with such an assessment often being reduced simply to the personal experiences of the examiner in question. It should also be pointed out that levels of English competence vary greatly among Ecuadoreans, producing somewhat of a lottery in the application of this doctrine.

An interesting case arose a several years back in relation to DISCOVERY COMMUNICATIONS, LLC’s enforcement of its ANIMAL PLANET mark for its well-known television series and documentaries about wild animals and domestic pets. Specifically, CENTRO DE RADIO Y TELEVISION CRATEL C.A., the company behind a national television channel in Ecuador, applied to register MUNDO ANIMAL in Classes 35, 38 and 41 (‘mundo’ means ‘world or ‘earth’). DISCOVERY opposed the applications on the basis of their Ecuadorian registrations for ANIMAL PLANET in Classes 38 and 41.

The oppositions were initially refused, following which all cases were appealed. Upon appeal before the IP Committee in Class 35, the authorities referred to studies as to the penetration of the English language in various countries around the world, saying that it would be incorrect to state that English had penetrated Ecuadorian culture. From there the reasoning was somewhat confused, but it was understood that the authorities considered the terms ‘animal’ and ‘planet’ as not easily understood by the general Ecuadorian public. This was quite an astonishing finding given that the the word ‘animal’ is the same in Spanish as in English, and that the Spanish for ‘planet’ is ‘planeta’. Clearly, this was the wrong starting point for deciding the cases.

It should be pointed out though that above Committee level decision contained a dissenting judgement from one of the Committee members, setting out in no uncertain terms that ANIMAL PLANET would be easily understood by Spanish speakers. The Committee is made up of three members, therefore the opposition was still rejected by 2 to 1. Nevertheless, dissenting judgements are rarely seen within such decisions, and needless to say the dissenting voice was encouraging for DISCOVERY, who decided to further appeal.

A reconsideration motion was filed against the mentioned decision, which is a request for the relevant authority to review its prior finding. Within such action, in contrast to the previous instance the authorities acknowledged that the meaning behind the mark ANIMAL PLANET would be easily understood by general Ecuadorian public, given the Spanish translation of the same is essentially identical except for the addition of the extra letter ‘a’ within the Spanish word ‘planeta’. The Office then went to conclude that the terms MUNDO and PLANET relate to an identical concept, and therefore that there was a risk that consumers would be confused. This reasoning was then followed within the related matters in Classes 38 and 41.

While the Ecuadorian trademark authorities’ acceptance that the meaning of ANIMAL PLANET can be deciphered by the average Ecuadorian consumer represents a welcome return to common sense, the Office’s position as a whole is interesting since the respective marks are being used on television programmes for content relating to animals. That is, in terms of inherent distinctiveness, the marks are towards the lower end of the spectrum. In addition, ‘mundo’ is not in fact a translation of ‘planet’, but rather means ‘world’ or ‘earth’. Therefore, the decision highlights that even in the case of non-literal translations, a conceptual link can still be inferred and be sufficient for a finding of confusing similarity. CorralRosales agrees with the decision, since it reflects the reality in that translations themselves are not always literal or direct.

A similar article was published in WTR on January 16th. Click to read it.

Ian Wall
Associate at CorralRosales
ian@corralrosales.com

Temporary Tax

temporary-tax

Regulation NAC-DGERCGC 20-00000004 issued by the Internal Revenue Service and published on January 29, 2020 in the Supplement of the Official Registry 131 establishes the procedure for filing the tax return and paying the temporary tax.

The Regulation establishes that the temporary tax that must be paid on an annual basis on the fiscal years 2020, 2021 and 2022.

The taxable base is equal to the income obtained on the fiscal year 2018 -as registered in the income tax return or as established by the Tax Administration within an assessment procedure- less the exempt income and income not subject to income tax. To this amount the taxpayer should add or deduct, as appropriate, the adjustments for deferred taxes registered in the same fiscal year.

The following rates must be applied to the taxable base:

Taxable income from 

Taxable income until

Tax rate
US$1.000.000,00 US$5.000.000,00 0,10%
US$5.000.001,00 US$10.000.000,00 0,15%
US$10.000.001,00 Forward 0,20%

The value of annual each contribution cannot exceed 25% of the income tax generated in the fiscal year 2018.

Those taxpayers who did not generate income tax in the fiscal year 2018 are not required to file and pay the temporary tax return. The advanced income tax shall not be considered if the amount was higher than the income tax generated.

If the amount of the taxable income or the amount of the income tax declared in the income tax return filed for the fiscal year 2018 changes, a substitute tax return must be submitted.

If the entity is liquidated before the date on which the temporary tax return must be filed, the tax must be paid in advance with respect to the fiscal year in which the liquidation takes place. Entities liquidated until December 31, 2019 are not required to pay the temporary tax.

CORRALROSALES

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Law for Simplification and Progressivity of the Tax Regime

progressivity-tax-regime

Below we will analyse the Law for Simplification and Progressivity of the Tax Regime published on December 31, 2019 in the Supplement of the Official Registry 111, amended the Internal Tax Regime Law.

Dividends:

Dividends distributed to individuals with tax residence in Ecuador and entities and individuals located abroad are subject to income tax. Only dividends distributed to entities with tax residence in Ecuador or permanent establishments located in Ecuador are exempted from income tax.

The taxable income is equal to 40% of the dividend effectively distributed. The concept of global dividend is eliminated (dividend distributed plus taxes paid by the company) and consequently the tax credit for taxes paid by the company.

Dividends distributed to individuals with tax residence in Ecuador are subject to up to 25% withholding. The Tax Authority will issue a regulation establishing the withholding percentage applicable, according to the amount of the dividend.

Dividends distributed to entities and individuals residing abroad will be subject to 25% withholding tax. However, if the Ecuadorian entity that distributes the dividends fails to report its corporate structure, the withholding percentage applicable to the dividend paid abroad will be 35%.

It is ratified that the capital increase with retained earnings (stock dividend) will not be taxed.

Interest Expense:

In the case of interest paid by banks, insurance companies and entities of the financial sector of the Popular and Solidarity Economy:

Interest that exceeds the interest rate established by the Monetary and Financial Policy and Regulation Board will not be deductible.

The total amount of the loans granted abroad -directly or indirectly- by related parties, may not be greater than 300% of the entity equity. Interest paid or accrued with respect to credits that exceed this percentage will not be deductible.

In the case of interest paid by entities or individuals, the total amount of the net interest paid on loans granted by related parties must not exceed 20% of the entity´s profit before labor participation, plus interest, depreciation and amortization corresponding to the respective fiscal year. Interest paid or accrued that exceed this percentage will not be deductible.

Creation a temporary tax to be paid:

  • How much should be paid? 

Entities that perform economic activities and whose taxable income in fiscal year 2018 are equal to or exceeded one million dollars.

  • How much should be paid?

The amount to be paid must be calculated according to the following chart:

Gross taxable income
from (US$) 

Gross taxable income up
to
 (US$)

Rate
1.000.000 5.000.000 0,10%
5.000.001 10.000.000 0,15%
10.000.001 Onwards 0,20%

The amount of the tax shall not exceed 25% of the income tax generated in the fiscal year 2018.

  • When should the tax be paid?
When should the tax be paid? The tax shall be paid annually during the fiscal years 2020, 2021 and 2022, until March 31st of each year. Failure to submit the tax form within the deadline will be sanctioned with a fine equal to US$1,500.00 for each month or fraction of a month. The fine will not exceed 100% of the contribution.

Important reforms

  • VAT on digital services:

Digital services are subject to 12% VAT. The taxable event occurs when: In the case of import of digital services, the taxable event occurs when the importer of the service -an entity or permanent establishment located in Ecuador- pays the service provider. In the case of delivery of goods, the taxable event occurs when the importer pays for the delivery services of such goods. The VAT will be applicable over the amount of such delivery services.

The VAT on digital services will be applicable starting July 2020.

Web domain services, hosting and cloud computing services are subject to 0% VAT.

  • Foreign Exchange Control Tax:

The exemptions of foreign exchange control tax were amended as follows:

  1. Investments from abroad made in the Ecuador stock market. These investments may be made in equity securities or in fixed income securities.
  2. Dividends: Dividends paid to entities or individuals residing in tax havens is exempted. This exemption is not applicable if the dividends are distributed to foreign entities which shareholder –directly or indirectly- are individuals or entities with tax residence in Ecuador which are shareholders of the entity that distributed the dividend.
  3. Payments made abroad for financial returns, and capital gains derived form:
    • Investments from abroad made in the Ecuador stock market. These investments may be made in equity securities or in fixed income securities.
    • Securities issued by entities domiciled in Ecuador, that were acquired abroad, destined to finance housing, microcredit or productive investments.
    • Fixed-term deposits or investments made with resources from abroad in local financial institutions.

This exemption does not apply if the payment is made between related parties.

CORRALROSALES

The use of cannabis has been approved in Ecuador

cannabis-regulatory-approved

In the 1st Supplement of the Official Gazette No. 107 of December 24, 2019, the Reform of the Criminal Law was published, which will enter into force in June 21, 2020.

Included among the reforms, is the decriminalization of possession of drugs that contain cannabis or derivatives as their active ingredient for therapeutic, palliative or medicinal ends, or for the practice of alternative medicine. In addition, the Law of  Control and  Prevention of the use of  Drugs   has been amended, excluding non-psychoactive or hemp cannabis from control, extended to the cannabis plant or any part of the plant, whose delta-9-tetrahydrocannabinol (THC) content is less than 1%.

The Ministry of Agriculture will have 120 days from the entry into force of this law to issue the regulations to control the import, planting, cultivation, harvest, sale, industrialization and exportation of industrial hemp. Furthermore, shortly the National Assembly must approve the Health Law, in which cannabis and its derivatives for medicinal and therapeutic use will be regulated.

CORRALROSALES

A Christmas Smile

Last Saturday, December 21, some members of the CorralRosales team volunteered at a Christmas party at San Vicente de Paúl Children’s Home. This state institution, managed by the Daughters of Charity of St. Vincent de Paúl Company, is responsible for the care and protection of up to 300 children between zero and twelve years of age.

CorralRosales firmly believes in corporate social responsibility; that is why we are always willing to be part of any humanitarian event or activity.

On this occasion, we decided to share our time, which is the most valuable thing we have. The volunteers of the CorralRosales team spent a day sharing activities, playing games and listening to these little children who need so much attention and love.

65 boys and girls from newborns to adolescents attended the event. They were able to enjoy an afternoon full of fun with a clown, magic tricks and live music. Together the CorralRosales team and the children sang the traditional Christmas carols, played with friends, and ate hamburgers and cotton candy; small pleasures the children thanked with smiles that lit up their faces as well as ours. And as it is to be expected at a Christmas celebration, Santa, Mrs. Clause and their helpers handed out gifts that included toys and clothes.

Without a doubt, it was an unforgettable and very emotional experience, not only for the little ones but also for the entire CorralRosales volunteer team. Having the opportunity to share time with these children reminded us of how fortunate we are and that we can find happiness in small things such as a smile, a hug or a laugh in the company of our friends.

Happy Holidays from the CorralRosales Team!

Solidarity Bike Race

solidarity-bike-race

Last Sunday, the CorralRosales team participated in the Niños de María foundation solidarity bicycle race.

As it has already become a tradition, on November 24 the Niños de María foundation organized its eleventh cycling race. Under the name “Record Niños de María, pedaleando por la educación de 300 niños”, hundreds of participants gathered to raise funds to pay for food and education of 300 children.

The Niños de María foundation, created in 1994 as a non-profit Catholic foundation, welcomes the most vulnerable children in our society into their schools and programs such as: the sewing project “Hilando Futuro”, choir, symphonic orchestra or folkloric dance.

CorralRosales is very committed to social causes. Therefore, we wanted to support this great solidarity initiative taking part in it, since all the money raised from the race registration will be used to support the Niños de María foundation school and projects.

“We decided to participate in this event not only because it allows us to put in our grain of sand and contribute to a better society, but also because it helps us strengthen ties between coworkers in a healthy environment,” says Verónica Fernández, Director of Human Resources of the firm.

The CorralRosales team, who wore a specially designed shirt for the occasion and competed under the business category of the race, was made up of both partners and administrative staff of the firm, and their families. The race route was 21-kilometer long and took place in the Chaquiñán de Cumbayá.

After the race, the team met again and was able to share some of the experiences and anecdotes of the day. Despite the fatigue from the race, everyone agreed with the words of one of the Partners of the firm, Francisco Gallegos: “It has been a pleasure to be able to enjoy an activity with family along with coworkers. Without a doubt an incredible experience that we recommend and that, of course, we are looking forward to repeating”.

solidarity-bike-race

solidarity-bike-race

solidarity-bike-race

solidarity-bike-race

solidarity-bike-race

Should filing a claim and not the summon interrupt the statute of limitation?

claim-summon-interrupt-statue-limitation

The amendment to the General Organic Code of Processes (COGEP), which entered into force on June 26, 2019, modified article 64(4) substantially modifying the interruption of the statute of limitations. Thus, before the reform, COGEP established that: “The effects of citations are… 4. Interruption the statute of limitations.” While after the amendment, it establishes that: “The effects of citations are… 4. Interruption of the statute limitations. If the lawsuit is summoned within six months of being filed, the interruption of the statute of limitations will be rolled back to the date in which the lawsuit was filed.”[1] Due to the amendment in reference, ¿is the right to legal certainty compromised?

Historically, the regulations governing civil procedures in Ecuador contemplated that the statute of limitations was interrupted only through citation. Since the first Civil Code enacted in 1869, until the last amendment to the COGEP entered into force, the citation of the lawsuit had been a concrete and verifiable date, that interrupted the statute of limitations. With the amendment, the interruption is rolled back to the date the lawsuit was filed, which is an unknown fact until the citation is made-, solely if the citation occurs within 6 months after the filing of the lawsuit. Keep in mind that the citation of the lawsuit is a fundamental factor, since only once it is achieved the litigation between the parties in conflict is locked and any legal terms begin to apply.

The Civil Code defines the statute of limitations as a way of acquiring goods or extinguishing rights for not having exercising those rights within the period determined by law[2]. Thus, a legal proceeding may be initiated within the time frame established in the law. If there were no statute of limitations, the right to legal certainty would be violated. It is the responsibility of citizens to initiate proceedings in due time and form or, to plead statute of limitation when having been sued and summoned once the legal term is exceeded.

Legal certainty implies, among other things, that the parties shall know the applicable rules when a process starts. The Constitutional Court has determined that “…the right to legal certainty is understood as the certainty in the application of the law that derives from the obligation of public authorities to respect the Constitution as a supreme law, and the rest of the legal system.” This right to know with certainty the enforcement of the existing norms in the legal system is violated the amendment since, rolling back the date for interrupting the statute of limitation to the moment the lawsuit was filed exclusively if the citation took place within six months, causes the defendant uncertainty.

For example, before the amendment, in a moral damage proceeding, were the statute of limitations ends 4 years after the perpetration of the act, the law allowed the defendant to know the legal framework for his defense. That is, the plaintiff was certain of the time frame stated in the law to exercise his right and initiate a proceeding. The amendment to the COGEP allows the interruption of the statute of limitation to take place not on the date the lawsuit is summoned, but on the date on which it was filed, undermining the defendant´s right to legal certainty.

To a greater extent, in the previous example, before the amendment, if the plaintiff filed a lawsuit for moral damage on the last day, that is, 3 years and 365 days, the statute of limitation would have ended. While with the amendment, if the lawsuit is filed on that same day, the statute of limitation would not have ended as long as the defendant is summoned within the following 6 months. That is to say, in the proceeding for moral damage, the plaintiff would have 4 years and six months for the lawsuit to be summoned and still rightfully exercise the respective proceeding, while before the amendment there were exactly 4 years to summon the defendant.

With the amendment of the article 64(4) of the COGEP, the legislator has allowed the lawsuit citation to interrupt the statute of limitation of the proceeding as long as the defendant is summoned within the following 6 months after the lawsuit is filed, which, in our criterion violates the constitutional right of the defendants for legal certainty.

Mateo Zavala
Associate at CorralRosales
mzavala@corralrosales.com


[1] COGEP, art. 64: “Art. 64.- Effects. The effects of the citation are: […]
4.” Interrupt the statute of limitations. If the lawsuit is summoned within six months of filing, the interruption of the statute of limitations will be rolled back to the date when the lawsuit was filed.”
[2] Art. 2392.- Statute of limitations is a way of acquiring things of others, or of extinguishing the actions and rights of others, for having possessed the things, or not having exercised said actions and rights, for a certain time, and concurring with the other legal requirements.

Counterfeiting and contraband

contraband-counterfeiting-eduardo-rios-corralrosales

The National Customs Service of Ecuador has recently created the Specific Task Force and the Customs Surveillance Corps to combat counterfeiting and smuggling, which seriously affect legitimate business activities as well as the Treasury.

A large majority of the counterfeit goods in Ecuador and in other countries of the region are imported, so those who introduce such items in the marketplace are in the majority of cases are committing the offence of dealing in contraband.

The local production of counterfeits in Ecuador, especially luxury brands and electronic products, is low. Therefore, most of the counterfeit products of recognized or luxury brands (wallets, watches, clothing, electronics, cell phone accessories, etc.) are manufactured outside Ecuador and their entry into the country is almost always illegal.

The illicit entry into the country of counterfeit products prompts the direct action of special Customs groups responsible for control and seizure, and destruction when appropriate. All this is done in order to remove from the market those products that, in addition to being illegal due to their origin, defraud the Treasury of tariffs and other taxes corresponding to imports.

Article 301 of the Criminal Code classifies the crime of contraband punishable by imprisonment for three to five years, and a fine of up to three times the customs value of seized products if said value is equal to or exceeds ten basic unified wages. (Currently US $ 3,940.00)

The same code establishes counterfeiting as an aggravating circumstance of the offence, in which case the maximum penalty will be imposed.

In an astute move, the National Customs Service of Ecuador created the “Specific Task Force”, made up of inspectors of the highest rank and proven reputation inside and outside the institution. This task force was also assigned auxiliary personnel that share the same characteristics and have demonstrated absolute honesty and dedication to their job.

A personal experience confirms what was stated above. On one occasion when the group had to wait approximately two hours to proceed with a seizure, members of the mentioned group decided to make good use of that time carrying out a fieldwork in the surrounding areas; this allowed them to seize more than 15,000 smuggled cigarettes that had entered the country. Having done that, they proceeded with the scheduled seizure.

In each counterfeiting case that we have worked on, we collaborated with Customs authorities providing information and identifying possible seizure targets. Also, when appropriate, the formal complaint was filed, and to prevent the counterfeit products from returning to the market, their condition was corroborated.

With our presence in the operations, offenders see their options to hinder the seizure procedure limited, because when the representatives of the brand owner certify that the seized products are counterfeit, there is no doubt or speculation about their origin.

Local industry and formal commerce in general have made a great effort to comply with mandatory technical regulations, especially labeling. This aspect is very helpful in prosecuting these offences because if the products do not meet the mandatory labeling requirements, they can be considered contraband. Therefore, their seizure is ordered, regardless of whether or not they are counterfeit.

We have decided to continue supporting Customs’ work in the fight against counterfeiting and smuggling, providing the tools to make their work more and more efficient. The constant training of personnel carrying out legitimate activities affected by these offences is another way of supporting the authorities in this work.

 

Eduardo Ríos
Senior Associate at CorralRosales
eduardo@corralrosales.com

The suspension of the administrative act on Intellectual Property

administrative-act-intellectual-property-ruth-holguin

The suspension of the execution of an administrative act is an exceptional provision that can be issued by an administrative or judicial authority. It is a precautionary measure that proceeds only when the execution of the administrative act produces unrecoverable or very difficult remediation losses due to the violation of the rights of the entity being administered. The suspension means that the administrative act does not apply until there is a final resolution.

This figure has limited application in the area of ​​Intellectual Property, since to obtain the suspension of the administrative act in judicial headquarters; the entities being administered must demonstrate that, for example, the registration of a trademark or patent violates their rights; or, that the registration of a trademark was improperly canceled due to lack of use.

A more detailed analysis:

  1. An opposition to a trademark or patent application might be provided by law for the following reasons: lack of distinctiveness, risk of confusion or association, not meeting the requirements of patentability, etc.
  2. The Ecuadorian Intellectual Property Office denies the opposition and gives way to registration, so that the affected party can challenge that decision before the Contentious Administrative Court, requesting, in addition, the suspension of the act, because the affected party considers that its execution would violate its rights in an irreparable way.
  3. If the request is granted, registration of the trademark or patent is suspended. After the judicial process, which has a minimum duration of three years, the sentence is issued. For the purpose of this analysis, we assume that the administrative resolution is ratified, granting the registration and denying the opposition.

In this scenario, did leaving the applicant without the ownership of his registration for three years violate his rights?

This would be the main conflict that could cause the suspension of the execution of an administrative act in Intellectual Property.

What happens in practice?

The judicial authority generally does not accept the request for suspension of the administrative act because, although the existence of irremediable loss caused by the execution of the act can be demonstrated, the rights of the person who obtained the registration of the trademark or the patent are also at risk.

It must be considered that most conflicts over Intellectual Property derive from trilateral administrative procedures, in which the administrative authority and two interested or administered parties intervene. Therefore, the suspension of the administrative act in this branch is especially controversial and unusual.

In summary, the substance of the dispute is that the contentious-administrative judge must assess whether or not the suspension of the decision of the administrative authority applies, taking into account the losses that could be suffered by both; the party that achieved the registration of the trademark or patent and the other party that considers their rights affected by that registration as well. There will always be an important degree of subjectivity, but the judge must receive comprehensive and true information from the parties in conflict to form his or her judgment.

Additionally, the judge that resolves the suspension of the administrative act, until there is a final decision on the conflict, should have the possibility of requiring sufficient guarantees to respond for the losses that may arise from the suspension if the final decision ratifies the resolution of the administrative authority. A reform to improve the application of the law would be to demand that enough guarantee´s be determined – the judge himself should set its amount – to grant the suspension of the administrative act.

Ruth Holguín
Asociada Senior en CorralRosales
ruth@corralrosales.com