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TAX AUDIT (ADMINISTRATION)

On January 01, 2009, the provisions which has long been introduced into the Tax Code (hereinafter the "Tax Code") will enter into force prescribing the mandatory extrajudicial procedure for appealing against decisions of tax authorities to subject a taxpayer to tax liability or to refuse to subject to tax liability.

Judicial appeal against such decisions is only possible after taking recourse to a higher tax authority.

In the event an appeal is filed with a higher tax authority, the decision being appealed enters into force only upon examination of the taxpayer's appeal application....

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