Tax Investigation Framework

The IRB issued a new Tax Investigation Framework effective 1 January 2023, replacing the previous framework dated 1 January 2020. The authorities will be focusing on selecting cases for tax investigation involving willful evasion and failure to submit tax return.

Below please find some prominent amendments:

The IRB may summon taxpayers or their related persons to obtain statements, which may be made at the taxpayer's business premises, at the taxpayer's residence, at the tax agent's/representative´s premises, at the premises of third parties, or at the IRB's offices.
Taxpayers will no longer have to make their payments to IRB officials. All payments from tax evasion must be made directly to the Director General of the Internal Revenue Service ("DGIR").
Taxpayers, agents, representatives, or witnesses may take their own notes during questioning or when filing a return.
For aggregate violations, payment of the tax, special penalty, and penalty surcharge shall be made in one lump sum to the DGIR. Taxpayers may also request payment in installments.

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