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If GTA refuses to satisfy your legitimate request, you may appeal the refusal within 20 calendar days from receipt of the refusal either with the Ministry of Finance or directly to the Court. If you do not receive a reply within 15 calendar days, the request is considered as rejected.
If you choose to appeal to the Ministry of Finance, the dispute may be resolved in the first instance by the GTA but may be escalated to the Disputes Resolution Board of the Ministry. In either case, both sides reserve the right to appeal to the Court at any time.
You or your authorized representatives are entitled to attend each stage of the appeal review process. The Revenue Service has 20 calendar days to review the appeal and 3 business days to send an official resolution to the taxpayer. If you do not receive a response from the Revenue Service within this deadline, the appeal is considered as rejected, and you have the right to object to the Revenue Service decision within 5 calendar days from receipt of the rejection or from the deadline within which it should have been received. The objection can be addressed to the Disputes Resolution Board or to the Court.
The Disputes Resolution Board or to the Court must make a decision on the appeal within 20 calendar days and send you the resolution within 5 business days. The resolution can be further appealed within 9 calendar days from its receipt. If not appealed, on the tenth day the resolution becomes effective.
If you choose to address the appeal to the Court, you must do this within the same deadlines established for appeal to the Minister of Finance (see above).
If you do not present your appeal within the deadlines at any stage of the dispute process, the notice or demand for tax payment or any other administrative-legal act under dispute, comes into force, and an appeal submitted without adhering to the deadlines will not be considered.
The liability to pay the amount under appeal, as well as accrued late payment fines and penalties, is halted during the appeal period but the accrual of late payment interest on the disputed amount continues.
If you appeal against a demand for tax payment, you must provide evidence that, within 20 calendar days from receipt of the notice, you have:
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