Article 193 establishes the 'procedural vs. substantive' rule for the transition phase. New procedural rules (such as for audits, objections, and suits) apply immediately upon the Law taking effect. However, the determination of the actual tax, income, or loss for any historical tax year must follow the 'substantive' rules that were in force during that specific year. For cases currently under review, the new dispute procedures apply unless a decision or judgment was already pending. This ensures that taxpayers are assessed fairly based on past laws while benefiting from modern procedural rights and timelines.
Part 8 - Miscellaneous and Transitional Provisions
Article 193
[GTL Notes: Application of Rules for Procedures in Transitional Phase]
The rules for procedures specified in this Law shall be applied from the date on which this Law takes effect. However, the determination of taxable income or loss or tax or additional tax shall be made by following the substantive rules which were in force for the tax year for which such determination is to be made.
The rules for procedures governing the examination of objections, contestations and suits and decisions thereon specified in this Law shall apply to the objections, contestations and suits under examination on the date on which this Law comes into force unless they are deferred for the issuance of the decision or pronouncement of the judgement.
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