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Resolving Tax Doubts in Favor of the Citizen

New regulations introduce a principle that in tax proceedings initiated by the authorities, any factual ambiguities will be resolved in favor of the citizen. This aims to increase legal certainty and protect taxpayers' interests, unless specific exceptions apply, such as conflicting party interests or significant public interest. These changes also apply to ongoing cases.
Key points
Factual doubts in tax proceedings will be resolved in favor of the citizen.
This principle does not apply when parties have conflicting interests, regulations require the citizen to prove facts, or it contradicts a significant public interest.
The new rules also apply to tax cases that are already ongoing but not yet concluded.
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VOTING RESULTS
2025-09-12
For 427
Against 0
Abstain 0
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Status:
Enacted
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Additional Information
Print number: 10_1265
Process start date: 2025-05-19
Voting date: 2025-09-12
Meeting no: 40
Voting no: 87