At the administrative level, the deadline is 30 labour days (Monday to Friday excepting public holidays) from the date of the assessment notice. At the judicial level, the deadline is 90 labour days (Monday to Saturday excepting public holidays). If the taxpayer files administrative tax appeals, the 90-business day legal deadline is suspended. Under some circumstances, it is also possible to file a reconsideration recourse against the first administrative decision within five business days from the notification of the decision.
- Administrative: administrative recourse, before the tax authority
- Judicial: judicial procedures before the Tax Court, Court of Appeals and Supreme Court
From the service of the assessment, and assuming the taxpayer has filed both administrative and judicial recourses, the average time for reaching a final decision is six to seven years (including all the judicial steps).
- Start: Taxpayer affected by a measure adopted by a Double Tax Agreement (DTA) party may initiate a MAP procedure, being domestic remedies still available.
- Conduct of the proceedings: Competent tax authorities conduct MAP proceedings.
- Completion of proceedings: If a MAP has been resolved for the taxpayer, it is possible to request the tax authorities to return the overpaid taxes.
- Other actions: N/A