Tax Disputes --- Appeal process A taxpayer may appeal to the Tax Court against the DGTs decision

n on the taxpayers objection within 3 months from the date of receiving the DGT decision. To the extent that the DGT Objection Decision calls for a payment of tax due, according to the Tax Court Law, at least 50% of the tax due must be settled before filing the Appeal. As set out in the current Tax Administration Law, the taxpayer is only required to pay an amount agreed in the tax audit closing conference. This creates a mismatch, however currently the Tax Court generally follows the Tax Administration Law. When the appeal is received partly or wholly, all as defined in the debt tax SKPKBT and SKPKB paid and resulted in excess payment of tax, tax overpayment is returned added interest of 2% (two percent) per month, maximum 24 (twenty-four) months calculated from the date of issuance of the tax payment until the objection decision or appeal decision. 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 Tax Court will conduct hearings on the appeal and has to decide within 12 months of the appeal being lodged. In certain special cases, this deadline can be extended up to three months.