Making appeals against advance rulings and special permits
When you receive the decision on an advance ruling or special permit, instructions for appeal are enclosed with it. The instructions indicate the appeal time limits and other information necessary for lodging an appeal.
A company, a corporate entity or an individual taxpayer can appeal against a binding advance ruling issued by the Tax Administration on a specific tax matter, or on a special permit.
The appeal authority is the Administrative Court. The appeal period is 30 days from the date when you receive notice of the decision. More detailed instructions for lodging an appeal are enclosed with the decision letter. In some cases, the Tax Administration decides to refrain from issuing an advance ruling. This is a decision against which no appeal to the Administrative Court can be made.
If a decision on a special permit is issued to you in matters related to tax-deductions for business losses or to the use of credits of corporate tax, you can submit a claim for adjustment to the Assessment Adjustment Board in order to request changes. The appeal period is 60 days from the date when you receive notice of the decision. More detailed instructions for submitting the claim for adjustment are enclosed with the decision letter.
Not only the taxpayer but also the Tax Recipients’ Legal Services Unit is entitled to lodge an appeal against a Tax Administration’s advance ruling or decision on a special permit. The appeal period begins on the date when the decision is made.
The parties’ general rights to make an appeal are unaffected by the advance ruling itself and whether or not the parties comply with the ruling’s contents and guidelines. This means that you can appeal against a tax decision in the usual way even if your taxes have been assessed in accordance with the advance ruling that had been issued.