background image
14.7. Appeal Procedures

A taxpayer may file a tax objection with the tax authority within 3 months from the date of the assessment. Taxpayers must settle at least the agreed amount stated in the tax assessment letter. If the taxpayer disagrees with the whole number, there is no need to settle the tax.

However, if a taxpayer fails in the objection process, it will be subject to a 50% administrative sanction of the tax unpaid at the time the objection is submitted. If the taxpayer challenges the objection decision to the next appeal process, the 50% administrative sanction will not be payable. The 50% sanction has been reduced to  30% by the Harmonized Tax Regulation Law issued in 2021.

The tax authority must respond to the objection application within 12 months from the date of filing the objection.

A taxpayer may file an appeal to the Tax Court against any objection decision within 3 months from the date of receiving the objection decision.

In order to file an appeal, a 50% of the tax unpaid must be settled. If the appeal is rejected or approved in part by the Tax Court, the taxpayer must pay a penalty equal to 100% of the tax unpaid at the time the objection is submitted. The 100% sanction has been reduced to  60% by the Harmonized Tax Regulation Law issued in 2021.

The hearing process at the Tax Court must be completed within 12 months of the appeal being submitted. In certain cases, it can be extended for an additional 3 months.

Both the taxpayers of the tax authority may further challenge the Tax Court’s decision by filing a request for judicial review to the Supreme Court.