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May 15, 2026

SECTION 4 - TAX OBLIGATIONS

Chapter 2 - Filing Tax Returns

Article 11 Bis

An entity meeting the criteria specified by the Regulation must submit a report to the Authority on the minimum indicators of its core activities, in the manner and within the deadline specified by a decision from the Minister.

An entity shall be deemed not to conduct core activities in the state for any reported financial year in the following cases:

  1. If it does not submit the report specified in the first Clause of this Article.

  2. If it does not meet any of the minimum indicators of core activity specified by the Regulation.

  3. If it does not provide the Authority, upon request, with documentary evidence of these indicators.

The Authority may refuse to issue a tax residence certificate to an entity that does not meet the minimum indicators of core activity.