GTL Summary:

Ministerial Decision No. 55 of 2025 defines the methodologies available to the Tax Administration for verifying compliance. Article 96 authorises the authority to conduct comprehensive audits of all Taxpayer returns. Additionally, it permits the use of sampling-based audits, which must be executed in accordance with specific criteria established by the Administration. This dual approach ensures the Tax Administration can effectively monitor MNE Group compliance through both targeted deep-dives and broader systematic checks.