Taxpayers have been given another opportunity to settle their tax disputes with the tax authorities—without going to court—following the extension of the Out-of-Court Tax Dispute Resolution Committee. Until January, they can arrange their debts with a discount of up to 75% on additional taxes, interest, and surcharges, and repay the remaining amount in up to 24 monthly installments.

The draft bill, released for public consultation yesterday, outlines in detail every step of the procedure handled by the special committee: the examination stages, the taxpayer’s obligations, and the legal consequences of accepting or rejecting the proposed settlement. The committee reviews requests and objections related to additional taxes, fines, interest, and surcharges, relying on case law and the established practice of the tax administration.

How the process works

The procedure begins with an examination of the taxpayer’s claims. The committee may recommend full, partial, or no acceptance of the request and prepares a detailed proposal listing all amounts involved (main tax, additional taxes, interest, surcharges, fines). The proposal includes an explanation and is sent to the taxpayer, who has five working days to accept it.

If the taxpayer accepts, the settlement document is signed and they select the number of installments. A formal out-of-court settlement record is then issued and—according to the bill—published on the Ministry of Finance’s website. This record acts as an enforceable title: the original debt is deleted and the new one is confirmed.

For the settlement to become legally binding, the taxpayer must pay at least 30% of the main tax or 25% of the standalone fine within ten working days. Any amounts already paid are offset. If the taxpayer fails to meet any condition—or delays two consecutive installments or the final two installments—the settlement is cancelled retroactively and the original debt is reinstated.

Discounts based on number of installments

The debt may be paid in up to 24 installments, with discounts structured as follows:

• 75% for payment in 1 installment
• 65% for 2–4 installments
• 55% for 5–8 installments
• 50% for 9–12 installments
• 45% for 13–16 installments
• 40% for 17–20 installments
• 35% for 21–24 installments

If the taxpayer does not accept the proposal

If the taxpayer rejects the committee’s proposal, a record of non-agreement is issued, and the suspended court case continues at the request of either party. If neither side asks for the case to continue within 60 days, the case is dismissed.