The Revenue Administration ("Administration") has
published a Draft of General Communiqué on Tax Procedural
Law ("Draft Communiqué") on its website and seeks
public comments. The Draft Communiqué proposes principles
and procedures for electronic notification of documents issued by
tax authorities according to Article 107/A of Tax Procedural Law
numbered 213 ("Tax Procedural Law").
According to the Draft Communiqué, electronically signed
documents, which the Tax Procedural Law requires to be notified,
would be served to a recipient's electronic notification
address via the electronic notification system from 1 January 2016.
Electronically signed documents would be deemed to be duly served
at the end of the fifth day after being sent to recipient's
electronic notification address.
Parties which the Draft Communiqué would require to use
an electronic notification address (and be eligible to be
electronically notified) are:
Income taxpayers, with respect to
commercial, agricultural and professional gain.
Other parties can also voluntarily ask to be notified
Corporate taxpayers must submit an Electronic Notification
Request Application ("Application") to the relevant tax
authority before 1 January 2016. The Application must be delivered
in person by the corporate taxpayer's legal representative or
someone appointed by a notarized power of attorney to perform
transactions in relation to the electronic notification system.
Corporate taxpayers incorporated after 1 January 2016 would be
required to submit the Application within 15 days of
Income taxpayers must submit an Application before 1 January
Deliver the Application personally to
the relevant tax authority or via someone who is appointed by a
notarized power of attorney to perform transactions in relation to
the electronic notification system.
After making an Application, taxpayers will receive a sealed
envelope containing an Internet Tax Office user code, a password,
Qualifying taxpayers must:
Complete the Application accurately,
completely and in a timely manner.
Notify of changes to information
already submitted. Notification must occur by the date of change at
Conform to all Application
Maintain confidentiality of the user
code, password and code, refraining from sharing these with third
Immediately inform the tax authority
if the user code, password or code is obtained by an unauthorized
From 1 October 2015, electronic notifications can be sent to
those who submitted their Application before this date. However,
the electronic notification practice will apply to all relevant
parties from 1 January 2016.
Failure to submit an Application will be subject to criminal
sanctions (Duplicated Article 335, in accordance with Articles 148,
149 and Duplicated Article 257 of the Tax Procedural Law).
Following a criminal sanction, an internet tax office account will
be formed ex-officio for the offending party.
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