The Department has the right to perform a field audit to ensure fulfilment by the taxpayer of obligations under the Income Tax Law.

Without prejudice to the provisions of other regulations, a field examination may be conducted for a taxpayer for the purpose of gathering information about another taxpayer.

The field examination shall be carried out during the working hours of the person subject to the examination, and the taxpayer is required by law to provide the information as requested by the Authority. The Authority also has the right to conduct the field examination of all the books and records of a taxpayer without prior notice.

The field examination may be performed at the taxpayer’s premises or the Authority’s offices based on an official notice by the Department. In the event that any books, records or documents are taken from the business premises, a receipt to that effect must be given to the taxpayer. An auditor from the Department may also visit the taxpayer’s location to verify the nature of the taxpayer’s business.

If a taxpayer keeps their books and records on an electronic media, they must provide the Authoriy’s auditor(s) with a hard (paper) copy of the requested information when requested.

[If a taxpayer, subject to field audit, does not cooperate in providing the requested information, the Authority shall coordinate with the competent authorities to compel it to cooperate and provide the required information. The Authority may also retain those documents if there is reason to believe that the taxpayer may attempt to conceal, destroy or tamper with them.]^[47]

Upon completion of the audit, the documents shall be returned to the taxpayer within 15 days from the end of the audit. The Authority may keep copies of documents or entries, as needed.

If the Authority does not agree with the taxpayer’s declaration, it will notify the taxpayer of the amendments made to the tax return, reasons thereof, and the amount of tax and penalties resulting from such amendments, and of the taxpayer’s rights to object. The notice shall be delivered by registered mail or any other means that confirms receipt of the notice by the taxpayer.

Without prejudice to the provisions of Article 65(b) of the Income Tax Law, the return is considered accepted by the Authority if five years have passed from the end of the prescribed deadline for submission without the taxpayer having received any notice from the Authority regarding the return.

Mathematical and material errors may be corrected within ten years from the end of the deadline for submitting the tax return for the relevant tax year. The correction could be requested for by the taxpayer, or as a result of detection by the Authority or audit agencies.

“Mathematical and material errors” refers to errors arising from arithmetic operations, such as addition, subtraction, multiplication and division, or of posting an erroneous number or similar errors.

The Authority may correct an error in the application of the Income Tax Law and regulations within five years from the end of the deadline for submitting the tax return for the relevant tax year, either upon request by the taxpayer, or as a result of detection by the Authority or by the audit agencies.