Guillermo Ruiz Zapatero

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Languages Known:

  • Spanish
  • English

Guillermo Ruiz Zapatero



Guillermo Ruiz has been a partner in the Tax Law Department of Garrigues since 1998, where he has pursued his professional career following a period in central government (1982-1987) and Price Waterhouse (1987-1989). He specializes in tax law, with particular focus on tax proceedings and lawsuits at all jurisdictional levels. He has also participated and continues to be involved in M&A transactions and the provision of on-going and specialized advice on tax matters. As regards the latter area, he has closely worked on proceedings concerning the application of general anti-avoidance provisions in the tax field and in the areas of tax offenses and special taxes.

He has been a member of the Madrid Bar Association since 1990.



Academic background:

Degree in Law, Universidad Complutense, Madrid.

Civil servant (leave of absence) at the Ministry of Finance.

Non-practicing member of the Spanish Institute of Certified Public Accountants.


Guillermo Ruiz has authored numerous publications, including those listed below.

Individual works (*):

  • "Analogy, Fraud and Sham Businesses in Tax Offenses: Supreme Court and Constitutional Court Judgments 120/2005". Aranzadi. April 2006.
    Sham Businesses and Tax Offenses. Commentary on the Judgments of the Supreme Court dated July 15, 2002 and April 30, 2003. Cuadernos de Jurisprudencia Tributaria no. 34. Aranzadi 2004.

Collective works (*):

  • "Commentary on the Tax Management and Inspection Regulation"s. Wolters Kluwer España, S.A., 2011. Garrigues, 2011. Coordinator: Abelardo Delgado Pacheco

Specialist journals (*):

  • "The effects of unconstitutional tax laws". Revista de Administración Pública no. 169/2006. January-April 2006.
  • "The Supreme Court judgment of February 22, 2012 on electronic notifications vis-à-vis the State Tax Agency". Quincena Fiscal Aranzadi no. 13/2012.
  • "Tax enforcement without record of title: Constitutional Court judgment 38/2011. Quincena Fiscal Aranzadi no. 7/2012.
  • "Interim and final justice in tax penalties". Actualidad Jurídica Aranzadi no. 841/2012.
  • "Compulsory tax notification to a designated e-mail address". Quincena Fiscal Aranzadi no. 5/2012.
  • "Compulsory tax notification to a designated e-mail address". Actualidad Jurídica Aranzadi no. 834/2012.
  • "Unreasonable delay in the resolution of appeals against tax penalties according to the ECtHR (“Impar Ltd. v. Lithuania”)". Quincena Fiscal Aranzadi no. 15/2010 - 16/2010.
  • "Review of final court decisions that are incompatible with judgments of the ECtHR and ECJ". Quincena Fiscal Aranzadi no. 6/2010.
  • "Community law as law of constitutional ranking and relevance and the Supreme Court judgment of January 30, 2008 ("transportes urbanos y servicios generales SAL").  Quincena Fiscal Aranzadi no. 1/2009 - 2/2009.
  • "Substantive and procedural bis in idem in the continuation of administrative proceedings due to the lack of a finding as to the existence of a tax offense". Quincena Fiscal Aranzadi no. 9/2009.
  • "Prohibition on double penalties in the tax field (“Ruotsalainen v. Finland”)". Quincena Fiscal Aranzadi no. 21/2009.
  • "How can the Constitutional Court maintain, in an appeal for the protection of constitutional rights (judgment 91/2007), tax rules that it had previously held to be unconstitutional without infringing articles 14 and 24 (besides 31) of the Spanish Constitution?". Jurisprudencia Tributaria Aranzadi no. 12/2007.
  • "The amendment of article 108 of Securities Market Law 24/1988 and the constitutional limits on the establishment of taxes according to the Constitutional Court". Jurisprudencia Tributaria Aranzadi no. 10/2007.
  • "Will a tax appeal for the protection of constitutional rights be of “constitutional importance”?". Jurisprudencia Tributaria Aranzadi no. 17/2007.
  • "Constitutional nature and limits of fair compensation for digital copying established in Law 23/2006 (RCL 2006, 1386) amending the revised Intellectual Property Law". Jurisprudencia Tributaria Aranzadi no. 7/2007 - 8/2007 no. 15/2007.
  • "Criminal safeguards, tax fraud and the case law of the Constitutional Court". Jurisprudencia Tributaria Aranzadi no. 18/2006 no. 19/2006.
  • "Inheritance tax on fiduciary relationships in Aragon in the Supreme Court judgment of March 31, 2004 (RJ 2004, 2682)". Jurisprudencia Tributaria Aranzadi no. 20/2004.

(*) originally published in Spanish

He is also the author of the blog