CHAPTER 16 - OBJECTIONS, GRIEVANCES, AND APPEALS
Article 107 - Tax Settlement Agreement
Without prejudice to the fines and penalties stipulated by the Law, the Tax Administration may agree with the Taxpayer on a settlement regarding the Tax Due in accordance with the following conditions and controls:
A memorandum must be prepared proving what the parties have agreed upon regarding the amount of the Tax (Top-Up Tax) and the basis of its calculation.
The Tax Administration will issue an amended assessment in accordance with the agreement, and the Tax stated in the amended assessment will be considered final, which the Taxpayer must pay.
If the agreement is reached during the grievance, the Tax Administration must notify the TGC of what has been agreed upon, along with a memorandum of settlement.
It is a condition while agreeing on a settlement during the appeal before the court that no final judgment be issued, and the memorandum of settlement must be submitted to the competent court.