The Federal Tax Authority (FTA) has clarified specific circumstances under which the statutory deadlines for submitting a tax assessment review request or a request for reconsideration may be extended. According to the relevant decision, the FTA may approve an extension if a taxpayer is unable to meet the prescribed deadlines due to the following exceptional circumstances:
- the occurrence of an accident or serious illness affecting the authorized signatory;
- the death of the authorized signatory, their legal representative or any first- or second-degree family member;
- a temporary business disruption beyond the taxpayer's control;
- the destruction of records due to a disaster;
- a general malfunction in the FTA's systems;
- the sudden loss of business records or discontinuation of business operations due to the implementation of a new computer system;
- a request by the FTA for additional documents, provided that the taxpayer can demonstrate the inability to procure them within the legally mandated timeframe; and
- a force majeure event, as determined at the FTA's discretion.
Conversely, the decision stipulates that the FTA will not grant an extension in the following cases:
- the taxpayer's lack of awareness regarding their obligations;
- delays caused by the negligence of a third party, such as a tax agent or legal representative, on whom the taxpayer relied;
- the complexity of the tax assessment review request or request for reconsideration, leading to the taxpayer's inability to submit it on time; and
- the taxpayer's preoccupation with business activities.
The clarification of the specific circumstances in which the statutory time limits for submitting a request for a review of the tax assessment or a request for reconsideration apply will come into force from 1 March 2025.
Source: IBFD Tax Research Platform News