The Tax Administration may conduct a comprehensive audit of all Taxpayer returns, and it may also audit based on sampling in accordance with criteria it sets.
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May 15, 2026
Ministerial Decision No. 55 of 2025 defines the methodologies available to the Tax Administration for verifying compliance. Article 96 authorises the authority to conduct comprehensive audits of all Taxpayer returns. Additionally, it permits the use of sampling-based audits, which must be executed in accordance with specific criteria established by the Administration. This dual approach ensures the Tax Administration can effectively monitor MNE Group compliance through both targeted deep-dives and broader systematic checks.
CHAPTER 15 - TAX AUDIT AND ASSESSMENT
Article 96 - Tax Audit Methods
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