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Inquiries & hearing

Inquiries & hearing

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The Regional Director reviewing the Administrative Claim may request for further information, and must invite the taxpayer to exercise his right for inspection of the file and/or his right to be heard, provided that such request is made in the Administrative Claim (which we recommend to include). As long as the Regional Director has not made his decision, taxpayers may add arguments and grievances to the Administrative Claim.


Further investigations by the competent tax authorities

As noted earlier, when filing an Administrative Claim, the file is being handled by the competent tax authorities that are supposed to take into account the principles of good administration, including the impartial review of the positions of the tax inspector and the taxpayer. As such, the competent tax authorities are allowed to make further RFIs as deemed necessary (including information from third parties).

Right of inspection and/or Right to be heard

When requested for in the Administrative Claim, the competent tax authorities must invite the taxpayer (or his legal representative) to exercise the taxpayer’s right of inspection (of the tax inspector’s file) and/or the taxpayer’s right to be heard (discuss the argumentation with the Regional Director). In our experience, exercising these rights tend to be very fruitful.

Additional arguments and grievances

It is important to note that as long as the Regional Director has not made his decision, the taxpayer may add further arguments or grievances to the initial Administrative Claim.

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