Three in ten taxpayer who appealed to the Dispute Resolution Department (TEN) of the Independent Public Revenue Authority (AADE), in order to re -examine their tax affairs, eventually achieved cancellation finessurcharges and extra taxes imposed by the competent audit bodies for tax offenses. Only the time -consuming process of administrative courts remained for the rest.
In January – April 2025, 2,913 appeals were referred to the TEN, of which 1,969 were examined. The justified taxpayers were 577, ensuring total or partial deletion of taxes, increases and fines.
The 1,368 appeals were rejected by the TEN. Many of the rejected appeals had been submitted by freelancers who demanded the cancellation of their imputed tax calculation system. Also, 15 appeals were implicitly rejected because it exhaled the 120 -day margin for their examination and 9 cases were filed for the resignation of the refugees.
Those taxpayers who do not find their … right in the TEN have a second chance in the administrative courts where according to AADE data, 40% of those who lose cases in the dispute resolution.
The appeal to the TEN is submitted within 30 days of the date of issuance of the tax administrative determination. Then the right to appeal is lost and the taxpayer cannot even appeal to the administrative courts. Also, in order for the controller to appeal to the TEN, he will have to pay 50% of the taxes and fines on the audit and if justified, the amount is refunded.
Since 2013, when the TENs began operating until the first quarter of 2025, a total of 96,162 appeals have been submitted, 91,676 of which were heard. Of these, in 22,785 cases (about 25%), the TEN annihilated the decisions of the taxpayer and justified taxpayers. The courts came up with 37,262 tax disputes cases while 4,489 cases are pending.
The “landscape” of the appeals at the TEN is expected to change gradually, as there is now an alternative to the taxpayer’s acceptance of the tax audit with a “bonus” haircut of up to 50% of the fine imposed on him.