At the end of a tax audit, the tax auditors will provide the taxpayer being audited with a written notification of the tax audit findings containing their proposed tax audit corrections. If there is a disagreement regarding the tax audit findings,

the taxpayer must respond to the notification in writing within seven to ten working days prior to attending a closing conference (the final discussion) with the tax auditors.

In the closing conference the taxpayer may reassert its position with regard to the tax audit corrections and present the relevant supporting documents. If there is still a dispute during the discussion of the tax audit findings, the taxpayer may request a discussion with the Quality Assurance Team (QAT) from the Regional Tax Office. The Discussion will be recorded in a memorandum prepared by the QAT.

The tax auditors may change some of the suggested corrections in light of the taxpayer’s response to the tax audit findings notification, the discussion result with the QAT and the closing conference discussion.

The results of the final discussion are then summarized in a closing conference document. The taxpayer will have to state Agree or Disagree to each of the proposed corrections in the document. The document should also set out which part of the taxpayer’s arguments are accepted by the tax auditors and accordingly lead to the cancellation or reduction of some particular suggested corrections. By the end of the closing conference, the tax auditors and the taxpayer have to sign the closing conference document.

The closing conference is to be completed a maximum three weeks from the initial invitation on date.

The corrections agreed to in the closing conference document will constitute a basis for the minimum amount the taxpayer must pay of the tax assessment issued based on the document.