If a taxpayer disagrees with a decision of the tax authorities it is possible to appeal against this decision. The first phase is an administrative appeal with the tax authorities. This appeal must be filed within six weeks from the date of the disputed decision. This appeal must contain certain data, such as the name and address of the plaintiff, a date, a description of the appealed decision and a motivation of the appeal. Upon request, the tax authorities must hear the appellant. A decision should be taken within six weeks after the expiry of the appeal term, but the tax authorities have the option to extend this term by a further six weeks (and even longer under circumstances).
If the administrative appeal does not resolve the issue, the taxpayer may initiate a judicial appeal in first instance. The same terms (deadlines) apply for the judicial appeal procedure, although in practice the decision of the court will usually not be rendered within the deadlines set out by law. The plaintiff can further appeal against a decision of the court in first instance to the Court of Appeals, which is again governed by the same procedural rules as set out above. As a final resort it is possible to appeal to the decision of the court in second instance to the Dutch Supreme Court. It is important to note, however, that the Supreme Court does not judge factual situations but only treats questions of law.
If the outcome of the administrative or judicial procedure leads to the repayment of taxes to the taxpayer, no interest will be granted on the repayment. On the other hand, it is possible to request the deferral of payment of the taxes claimed by the government during the course of an appeal procedure.