Appeals are submitted exclusively to the Tax Appeals Directorate, which, since January 1, 2017, has been part of the structure of the Ministry of Finance.
1. You must possess a document (issued by the tax administration) that affects the taxpayer's interests.
2. The appeal must be filed within one month of becoming aware of the administrative act sent by the tax administration.
3. Within this one-month period, you must pay or provide a bank guarantee for the liabilities specified in the assessment notice, including late payment interest up to the payment date. Fines do not require pre-payment or a bank guarantee.
Warning! Without these documents, the Appeals Directorate will reject the appeal.
1. Any "Tax Assessment Notice" sent by the tax administration that you deem unfair.
2. Any act affecting the taxpayer's request for a tax refund.
Any act affecting the taxpayer's request for tax relief.
4. Errors made by the administration in calculating the percentage of late payment interest.
5. The imposition or calculation errors of various types of fines.
6. An appeal may also be filed against omissions (inaction) by the tax administration that affect the taxpayer's tax liability.
Warning! Administrative measures related to the forced collection of tax liabilities cannot be appealed. These include:
a. Bank account blocking orders;
b. Notices and demands for payment;
c. Notices to third parties and administrative acts related to the confiscation of goods.
1. A written request describing the claims, including the taxpayer's name, address, and Fiscal Registration Code (NUIS), signed at the end.
2. The administrative act issued by the tax administration.
3. Proof of payment of the liability and interest (bank payment order). In the absence of payment, a bank guarantee covering the liabilities and interest.
4. Supporting information such as audit reports, official records (minutes), and findings acts.
5. Any other document the appellant deems important for a fair resolution of the case.
The appeal can be delivered in person or sent via registered mail. The submission date is considered the date of protocoling for in-person deliveries, or the postmark date for those sent by mail.
Warning! The taxpayer must provide proof of the date they received the administrative act being appealed. Proof may include the envelope copy, postal registration records, etc.
1. During the review, the Appeals Directorate may request additional documents; the taxpayer is obliged to comply.
2. The burden of proof to contest the tax administration's assessment lies with the taxpayer.
3. If the appeal deadline is missed, the taxpayer must argue and prove with documentation that the delay was not their fault.
4. Upon reinstatement of the deadline, the appeal must be filed within 15 days (not one month as per the initial deadline).
If the taxpayer wishes to be heard orally, they may request a hearing in their written appeal.
Source: General Directorate of Taxes.