On 6 October 2026, the NTB reiterated the statutory provision under the Administrative Appeal Act and the Tax Collection Act allowing taxpayers to suspend the transfer of tax arrears to compulsory enforcement by filing an administrative appeal (visa) and simultaneously paying at least one-third of the tax amount determined in the reconsideration decision. This provision applies to both profit-seeking enterprise income tax and individual comprehensive income tax cases. The deferral remains effective until the appeal is adjudicated by the MOF’s Appeal Review Committee or the Administrative High Court. Importantly, the one-third payment is not a deposit but a partial satisfaction of the assessed liability; any excess paid will be refunded with interest if the appeal succeeds. The guidance warns that failure to meet the payment threshold within 10 days of filing the appeal will result in immediate referral to the Administrative Enforcement Agency.
Key Takeaways
- Strict Payment Deadline: The one-third amount must be remitted within 10 calendar days of the appeal filing date; late payment invalidates the deferral automatically.
- Scope of Applicability: The rule covers national taxes (income tax, estate tax, gift tax) but excludes local taxes such as land value tax and house tax, which follow separate enforcement regimes.
- Interest on Refunds: If the appeal results in a reduction of the tax liability, the overpaid portion earns interest at the statutory rate (currently 1.5% per annum) from the payment date to the refund date.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement