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May 15, 2026

This rule, referencing Article No. 35 of the Executive Regulations, outlines the procedures for precautionary attachment. It specifies the reasons for which the Tax Department may apply for an attachment, namely when it fears its rights may be lost. Such reasons include the taxpayer's intention to permanently leave the country, cease or waive their business activity, or dispose of moveable or real estate properties to evade tax. The rule mandates that the procedures for issuing a precautionary attachment order must adhere to the legal processes stipulated in Law No. 38 of 1980.

Executive Rule No. 57 Concerning procedures for the implementation of precautionary attachment

Article No. 35 of the Executive Regulations

First: Reasons for the application of precautionary attachment:

If reasons arise causing the Tax Department to become concerned that its rights may be lost, such as:

The Tax Department becomes aware that the taxpayer intends to leave the country forever;
The Tax Department becomes aware that the taxpayer intends to cease or waiver its activity;
The Tax Department becomes aware that the taxpayer intends to dispose its moveable or real estate properties with the aim of evading the tax due.

Second: procedures for issuing an order for precautionary attachment:

This shall be subject to the legal procedures stipulated in the civil and commercial procedures Law No. 38 of 1980.