1. When is the first appeal deadline following disagreement of the assessment made by the tax authorities?
One month from the date of assessment notice
2. What is the appealing procedure?
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First stage: Compulsory administrative level.
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Administrative procedures have to be exhausted prior to recourse to judicial proceedings (three-six years).
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Judicial procedures.
4. How do the national tax dispute resolution proceedings interact with the international tax dispute resolution proceedings?
- Start: National or International DR can coexist initially.
- Conduct of the proceedings: Suspension of any national proceeding until the end of the MAP. Possibility to request the suspension of tax collection with guarantees and without interest meanwhile MAP procedure is in progress.
- Completion of proceedings. In general, arbitration decisions will be binding if the person directly affected accepts the decision and renounces the right to any other remedy (including national ones that have already commenced).
- Other actions. No possibility for national appealing against MAPs decisions, except for implementing actions.