Article 39

In accordance with the statute of limitations provided in the Law, the Authority has the right to inspect the tax returns of the taxpayer, the accompanying documents, and any other records, books, or data it deems necessary to verify compliance with the provisions of the Law and this Regulation. In doing so, the Authority may:

1. Invite the taxpayer or their tax agent to appear to discuss and provide any clarifications and information related to their activity and tax returns within a period specified by the Authority. Notes and clarifications provided will be recorded in a report prepared by the Authority for this purpose.

2. Require the taxpayer or their tax agent to submit any information, documents, books, records, or data needed for the inspection within (20) twenty days from the date of notification.

3. Visit the taxpayer's business location during business hours to conduct field inspections and examine the books and records maintained by the taxpayer.

4. Retain copies of any books, records, or paper or digital documents and seize their originals if the Authority finds it necessary.

5. Examine books, records, and data of the taxpayer for the purpose of gathering information related to tax due on another taxpayer.

6. Access and inspect software, systems, and applications used for recording the taxpayer's accounts and preparing their tax returns.

7. Access and inspect data and information necessary for the operation of these software, systems, and applications, as well as databases used in managing transactions, issuing invoices, revenues, receipts, assets, or inventories.

When conducting an inspection, the Authority must notify the taxpayer using a form prepared for this purpose, and such notification must be given at least (15) fifteen days before the start of the tax inspection. The advance notification must include the date of the inspection and the tax period(s) under audit.

The inspection/auditing process can be conducted at the premises of the Authority or the taxpayer, as decided by the Authority.

The taxpayer under inspection/audit has the right to:

1. Request the tax examiner to show their official ID.

2. Obtain copies of any original documents or records seized or acquired by the Authority.

The taxpayer undergoing a tax inspection must provide all necessary assistance and cooperation to the tax examiner to enable them to perform their duties effectively.

The Authority may use specialists and technical experts from government agencies or the private sector who are not competitors of the taxpayer if necessary.

Before issuing a tax assessment decision, the Authority may notify the taxpayer of the results of the tax inspection. The taxpayer must provide their observations on these results within no more than (30) thirty days from the date of notification and may request access to or copies of the documents and data that the Authority relied upon in adjusting and estimating the tax due.

The Authority may request foreign tax authorities to conduct simultaneous audits and inspections and may also conduct simultaneous audits and inspections at the request of a foreign tax authority, in accordance with the procedures and guidelines specified by the President.