GOOD LEGAL SOLUTIONS | LAW FINANCE TAX | GLS |

Every entrepreneur may face a situation where the tax authority determines a tax liability that they disagree with. In such cases, it’s essential to understand the appeal procedure and strictly observe the established deadlines to effectively protect your rights and avoid additional financial penalties.

When Is a Tax Liability Considered Agreed?

A tax obligation is deemed agreed in the following cases:

• Self-declared liability: If the taxpayer voluntarily declares the tax amount, it is considered agreed upon upon submission of the tax return.
• Assessment by the tax authority: If, following an audit, the tax authority issues an additional tax assessment and the taxpayer does not appeal it, the liability becomes agreed 10 working days after receiving the tax notice-decision.

⚠️ Agreed tax liabilities are automatically reflected in the taxpayer’s accounting card. In case of discrepancies, the taxpayer has the right to request a reconciliation or challenge the tax authority’s decision.

What to Do If You Disagree with the Assessment?

If you do not agree with the assessed amounts, you have the right to appeal:

1. Administrative Appeal:

• Deadline: Within 10 working days from the date of receipt of the tax notice-decision (TND).
• Submission procedure: The complaint must be submitted to a higher-level tax authority in writing or electronically. The authority that issued the decision must be notified of the appeal.
• Review period: The appeal must be considered within 20 calendar days, with a possible extension up to 60 days (with obligatory taxpayer notification).

2. Judicial Appeal:

• Deadline: The taxpayer can file a lawsuit within 1095 days from the date of receipt of the TND. If an administrative appeal was filed first, the lawsuit must be submitted within 1 month after its conclusion.
• During litigation: The tax liability remains unagreed until the court decision enters into legal force.

Why Meeting the Appeal Deadlines Is Critica

Failure to meet the deadlines results in the tax liability becoming automatically agreed and subject to payment. Unpaid agreed liabilities will accrue penalties and interest, and the tax authority may initiate enforced recovery procedures.

Recommendations for Entrepreneurs

• Track deadlines carefully: You only have 10 working days to appeal the tax notice — missing this window complicates the process significantly.
• Keep all documentation: All documents and correspondence from tax authorities must be properly preserved for potential use in an appeal.
• Seek expert advice: Consult qualified tax advisors or lawyers to ensure proper legal support throughout the appeal process.

💡 Timely and correct response to tax notices is a key element in protecting your business’s interests and maintaining financial stability.