Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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Egypt reintroduces the tax dispute resolution
On 28 July 2022, the Egyptian government published Law No. 153 of 2022 in the Official Gazette. The Law has amended the previous Law 79 of 2016 and extended the provision of tax dispute settlement until 31 December 2022. The tax dispute
See MoreNigeria issues new procedural rules for tax appellate tribunal
Recently, the Minister of Finance, Budget and National Planning issued new Tax Appeal Tribunal (Procedure) Rules 2021. The Rules replace the 2010 Rules and are intended to guide the practice and procedure of Tax Appeal Tribunal (“TAT“)
See MoreGhana updates tax appellate processes
Ghana’s Parliament has passed the Revenue Administration Act, 2020 (Act 1029) as an amendment to the tax procedures and administration rules. Previously, taxpayers only could appeal to the High Court of a tax decision made by the
See MorePakistan: FBR launches e-filing of appeals
On 2 January 2021, Federal Board of Revenue (FBR) of Pakistan has published a notice regarding the launch of the e-Filing of Appeals with effect from 1 January 2021. Commissioner Inland Revenue (Appeals) is the first tier of appellate hierarchy
See MoreMalaysia issues ruling on appeal against assessment and application for relief
On 7 October 2020, the Malaysian Inland Revenue Board (IRB) has published Public Ruling No.7/2020 with the objective to explain the procedures with regard to appeal and application for relief in line with the provisions of the Income Tax Act 1967
See MorePanama extends suspension of administrative appeals proceedings amid COVID-19 pandemic
The tax authority of Panama published Resolution No. 201-2353 of 2020, amending Resolution No. 201- 2270 of 2020 to extend the suspension of administrative appeals proceedings until the emergency is lifted due to the COVID-19 outbreak. Previously
See MoreMalaysia gazettes Labuan Business Activity Tax (Amendment) Act 2020
On 10 February 2020, Malaysia has gazetted the Labuan Business Activity Tax (Amendment) Act 2020 (“the Amendment Act”) which comes into operation on 11 February 2020. The following tax measures are included in the act. A company in Labuan
See MoreUK: Consultation on tax dispute resolution
On 2 July 2019 the UK government published for consultation draft Regulations to implement EU Council Directive 2017/1852 on tax dispute resolution mechanisms. Under the draft Regulations a stronger system of dispute resolution would be introduced
See MoreArgentina introduces installment payment option for tax assessment cases before the tax court
On 01 March 2019, the Federal Administration of Public Revenues (AFIP) has published General Resolution 4434 in the official gazette introducing an installment payment facility for tax liabilities in relation to tax assessments that are under
See MoreSaudi Arabia: Tax Authority set deadline for filing an appeal against final assessment order
In a recent assessment order, the GAZT indicated that the deadline for filing an appeal will be determined from the date that the assessment order is notified to the taxpayer through the ERAD system. Saudi Arabia’s General Authority of Zakat and
See MoreSaudi Arabia: Circular issued on implementation of recent tax law amendments relating to tax appeal procedures
General Authority for Zakat and Taxes (GAZT) of Saudi Arabia has clarified in its Circular No. 7258/16/1439 of 14 November 2017 that the appeal procedure under Articles 66 and 67 of the Income Tax Act is applicable until new Appeals Committees are
See MoreSaudi Arabia: Decree amending appeal procedure
Saudi Arabia issued Royal Decree No. M/113 of 25 July 2017 amending the country's income tax law with regard to penalties and appeals procedures. According to the Decree, the General Authority of Zakat and Tax is expressly given the power to impose
See MoreIreland: Revenue assessment in the absence of a return
On 19 June 2017, the Irish Revenue published the Tax and Duty Manual Part 41A-05-02 that has been amended in paragraph 1 in relation to the pursuit of outstanding returns and in paragraph 4 in relation to appeal provisions. According to this
See MorePakistan: FBR publishes a guideline on the mechanism of ADR
Recently, the Federal Board of Revenue (FBR) has issued a guideline on the mechanism of ADR. The FBR has motivated taxpayers to resolve their issues through the Alternate Dispute Resolution (ADR) mechanism, which will help taxpayers from unnecessary
See MorePakistan: Instigated the alternative dispute resolution committee
On 29 March 2017, the Federal Board of Revenue (FBR) has started the Alternative Dispute Resolution (ADRC) service. The FBR has decided to provide the service in view of the fact that 27,000 complaints are pending before Appellate Tribunal Inland
See MoreColombia: Procedure to request for amending tax returns
According to the decision 20960 of 2017, the Tax Court pronounced on the rules that must be followed by the National Tax Authority (DIAN) when analyzing taxpayers' requests for amending tax returns. Taxpayers may apply for amendment to a tax return
See MoreBrunei: MoF launches Income Tax Board of Review
The Ministry of Finance (MoF) announced the establishment of the Income Tax Board of Review, on 14 February 2017. The establishment aims to facilitate the administration and operation of taxation in Brunei Darussalam. The Income Tax Board of Review
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