Article 21

The President may, in cases where the collection of the tax is at risk of being lost, obtain an order from the judge of urgent matters to impose a precautionary seizure on the taxpayer's assets necessary to collect the tax and related financial penalties, whether in the possession of the taxpayer or others.

These assets are considered to be under precautionary seizure from the date the taxpayer is notified of the judge's order, and the taxpayer may not dispose of them unless the precautionary seizure is lifted by an order from the judge of urgent matters.

The taxpayer and interested parties may appeal the order imposing the precautionary seizure before the competent court within thirty days from the date of notification.