They act on the CC against the resolution of the SAT for harmonization of the DPI as NIT

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March 28, 2025March 28, 2025By Mario Vásquez
They act on the CC against the resolution of the SAT for harmonization of the DPI as NIT

The lawyer Diego Sagastume Vidaurre, announced that he presented the action of total unconstitutionality against the resolution of the Superintendence of Tax Administration (SAT) for the indistinct use of the Single Identification Code (CUI) and the Tax Identification Number (NIT).

The aforementioned resolution is identified with the SAT-DSI-393-2025 number, issued on March 7, 2025 and published in El Diario de Central America on the 17th of this month.

In this, the entity resolves the indistinct use of the Single Identification Code (CUI) and the Tax Identification Number (NIT), explained the lawyer.

ICI contains the digits that appear in the personal identification document (DPI).

Sagastume Vidaurre indicated that the presentation of constitutionality was personal with the lawyers Ricardo Sagastume Morales and Marcella Orr Solares.

He explained that unconstitutionality is presented for several reasons, but mainly, because the Unified Tax Registry (RTU) was created specifically by a Law of the Congress of the Republic for tax control issues, while the DPI was created in the Law of the National Registry of Persons (RENAP) in 2005.

In the latter, the replacement of the neighborhood card by the DPI with a unique identification code (CUI) was established for individual and specific civil identification purposes of a person.

“In any case, any change to be made must be made through a reform or issuance of a decree in the Congress of the Republic and not through a SAT resolution,” said the lawyer.

He said that with this resolution the principle of legality established in the Political Constitution is violated, with respect to the legislative procedure, since the SAT is attributing functions that do not correspond to it, and of the constitutional supremacy, such as the normative hierarchy.

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Sagastume Vidaurre expands his comments by indicating that “the only way to change what we have today is through a reform of laws (through Congress). There is no other mechanism or via, so the resolution of the SAT is unconstitutional and the Court of Constitutionality must declare it.”

The action is against the entire resolution because the main reason for this resolution is the adoption of CU as NIT.

“In short, the nature of each registry is different and the reform mechanism must be through Congress,” he concluded.

Meanwhile, the SAT recently explained that the objective of the resolution is normative and administrative and the purpose is to establish internal provisions to complete progressive harmonization. In addition, the entity must make harmonization in around 200 computer systems.

There are currently assets around 10 million 366 thousand nit.

Within these, in October 2023, NIT began to provide new taxpayers with the CUI digits.

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