Article 31 - Request for Review, Objection, and Appeal

Any person against whom a decision or procedure is issued by the Bureau may submit a review request to the Bureau within sixty days from the date of notification of the decision or procedure, subject to the review request, after paying the prescribed fee.

The Bureau shall issue its review decision on the review request within ninety days, and may extend this period for an additional similar period after notifying the concerned party. The concerned party shall be notified of the review decision regarding the review request through the methods prescribed in the Regulations, and the expiration of the specified periods without notifying the concerned party of the review result, shall be deemed as an implicit rejection.

The concerned party may object to the review decision issued by the Bureau on the review request before the Tax Objections Committee within sixty days from the date of notification of issuing the review decision by the Bureau, or from the date it is deemed rejected. The concerned party may also object to the decision or procedure issued by the Bureau against them before the committee, within sixty days from the expiration of the deadline for submitting the review request, after paying the prescribed fee.

The Committee shall issue its recommendation on the objection and submit it to the Minister or his delegate within ninety days from the date it is submitted to them. The Minister or his delegate shall issue a decision to approve, amend, or revoke the recommendation within thirty days from the date of its receipt. The concerned party shall be notified of the final decision regarding their objection through the legally prescribed methods. The expiration of the mentioned periods without notification of the objection result shall be deemed as an implicit rejection.

The concerned party may appeal the decision of the Tax Objections Committee before the competent court within sixty days from the date of notification of the decision, or from the date the objection is deemed rejected. The concerned party may also appeal the decision or procedure issued by the Bureau, or the decision made on the review request, before the competent court within sixty days from the date of the expiration of the deadline for filing the objection.

In all cases, the appeal before the competent court does not prevent the collection of the Tax Due or the administrative fine due subject to appeal, unless the court orders otherwise.

The Regulations shall prescribe the rules and provisions necessary for the application of the provisions of this Article.