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14.7. Appeal Procedures

Initial Appeal

A taxpayer may appeal an adjusted assessment with the tax authorities within 30 days of the issue of the assessment. When making an appeal, the taxpayer must include the following in a written notice of appeal:

  • Identify the specific matter contested
  • Specify in detail the grounds of the appeal

Payment of Tax Due

Regardless of an appeal by the taxpayer, any taxes due that are not in dispute must be paid within 30 days or any appeal will be void. The 30-day limit can be extended subject to approval.

Appeal Commission

If the appeal cannot be resolved between the tax authorities and the tax payer, it may be referred to the Appeal Commissioners, officials appointed by the Minister of Finance. Upon hearing the case, the Appeal Commissioners may reduce, confirm or increase the amount of the assessment.

Appeal to Circuit Court

If the taxpayer is not satisfied with the decision of the Appeal Commissioners, they can apply to have the appeal re-heard by a Circuit Court judge. Note, however, that if the appeal is dismissed by the Appeal Commissioners due to a failure of the taxpayer to supply required documents or information, the right to have the appeal reheard is not available.

High Court & Supreme Court

If the taxpayer is not satisfied with the result of the re-hearing of the appeal by the Circuit Court, an appeal can be filed with the High Court, and ultimately the Supreme Court. Appeals beyond the Circuit Court can only be filed on the matter of law, and not matters of fact.