Auditing system has improved
Appeals by taxpayers have been significantly reduced as disputed cases are dealt with faster
The unification of audit centers and their supervision by a strong central administration – which put an end to the expansive interpretation of circulars and legislation – as well as the previous decisions by the Tax Dispute Resolution Directorate (DED), have led to a significant reduction in appeals by taxpayers, as well as in how long it takes for them to get vindicated.
The DED, established by the country’s creditors, now functions as a small court that quickly makes decisions, mainly taking into account the decisions of the Council of State, even if they have not been “passed” legislatively by the Parliament. Those who now appeal to the DED know in advance that their appeal will have to be very well prepared or it will be rejected.
This can also be seen from the fact there has been a significant reduction in appeals by taxpayers requesting cancellations of fines because they submitted their tax return late, and in general cases where they themselves know that they will not be vindicated, as the tax legislation has been violated.
At the same time, tax audit reports have improved recently and leave no room for tax evaders to request the cancellation of an audit for formalities. Of course, there will always be cases of circumvention of the legislation due to errors by the auditors.
In 2023, 6,956 taxpayers and businesses appealed to the Dispute Resolution Directorate, challenging actions of the tax administration, when in 2020 10,028 had appealed.
Last year, 6,527 cases (out of 6,956) of taxpayers and businesses were examined, of which 1,946 or 29.8% were partially or fully accepted. This means that three out of 10 were partially or fully vindicated.
Another 4,268 appeals were rejected immediately, while 278 were implicitly rejected because they were not examined within the 120-day deadline. For 35 appeals the taxpayers subsequently declared resignation and the cases were shelved.
According to tax administration data, of those whose cases were rejected, 3,303 taxpayers and businesses have appealed to the courts.
