Article 164 specifies when a tax postponement expires. The deferral of payment ceases to be effective—and the tax becomes immediately due—upon two events: (1) the date specified in the new assessment issued after the objection decision, or (2) the date the taxpayer abandons the dispute. This ensures that the postponement is strictly temporary and is only valid as long as the dispute is active. Once a decision is made or the objection is withdrawn, the taxpayer must settle the outstanding balance according to the Authority's final determination.
Part 6 - Tax Disputes
Chapter 1 - Objection
Section 3 - Postponement of Payment of the Objected Tax
Article 164
[GTL Notes: End of Disputed Tax Payment Deferral]
The decision issued to postpone tax payment shall cease to be effective, and the tax shall become due from the due date specified in the assessment made giving effect to the decision on the objection, or from the date of abandonment of the dispute.
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