A taxpayer who does not accept the DGT Objection decision can file an Appeal (Banding) with the Tax Court within three months of the receipt of the DGT Objection. To the extent that the DGT Objection Decision calls for a payment of tax due, according to the Tax Court Law, at least 50% of the tax due must be settled before fling the Appeal. As set out in the current Tax Administration Law, the taxpayer is only required to pay an amount agreed in the tax audit closing conference. This creates a mismatch, however currently the Tax Court generally follows the Tax Administration Law.

The Tax Court will typically have to decide on an Appeal within 12 months. Any underpaid tax resulting from the tax court decision is subject to a surcharge of 100%.

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