The DGT, following a taxpayer’s Correction Request, or by virtue of its official position (ex-offcio), may correct or cancel a tax assessment letter, a STP, or their derivatives issued on the basis of those letters. The derivatives include, among others:

• Objection Decision Letters;
• Decision Letters on the Reduction or Cancellation of Administrative Sanctions;
• Decision Letters on the Reduction or Cancellation of Tax Assessment;
• Decision Letters on an Early Refund of Overpaid Tax.

The DGT must issue a decision on a Correction Request within six months of the date of fling. If no decision is issued

by the DGT within six months, the Correction Request is automatically deemed to have been approved by the DGT.

Taxpayers who do not (fully) accept the DGT Decision on a Correction Request can file a lawsuit with the Tax Court Gugatan) within 30 days of the receipt of the DGT decision.

A lawsuit against the DGT can also be fled with the Tax Court for the execution of Distress Warrant. In this case, the lawsuit must be fled no later than 14 days after the execution date.

The Tax Court must decide on a lawsuit within six months.