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May 15, 2026

Article 131 outlines the remedies available to the Tax Authority when tax avoidance (under Article 129) is identified. The Authority is empowered to: (1) issue an assessment for the full amount of tax avoided, (2) cancel any prior decisions to refund tax, and (3) demand the recovery of any previously refunded tax within a specified timeframe. Taxpayers have the right to dispute these corrective decisions. These powers ensure that the Authority can effectively nullify the financial benefits of avoidance schemes and restore the taxpayer's position to what it would have been without the avoidance transaction.

Part 4 - Avoidance of Double Taxation

Chapter 2 - Tax Avoidance between Persons or By Entering into Transactions

Section 2 - Cases of Avoidance by Entering into Transactions

Article 131

[GTL Notes: Tax Avoidance Adjustments]

The Authority, shall, in the case where Article 129 of this Law is applicable, make an adjustment as follows:

Make an assessment at the amount of tax avoided in full or in part.
Cancel any decision issued to refund a tax,
Require a refunded tax to be recovered within a period of time to be specified by the Authority.

The decision issued in this respect may be disputed in accordance with the provisions of this Law.