Subject of Dispute: Challenging a Tax Notification-Decision on Imposing a Penalty for Late Registration of Tax Invoices.
Main Arguments of the Court:
The Supreme Court pointed out the need to consider the principle of the rule of law and the prohibition of discrimination of taxpayers when applying penalties for late registration of tax invoices. The Court noted that from May 27, 2022, the rules for applying the moratorium on penalties changed, but the state did not create clear conditions for taxpayers regarding the registration of invoices drawn up before the introduction of martial law.
Court Decision: To cancel the decisions of previous instances and refer the case for a new review to clarify in detail all circumstances, in particular the correctness of calculating penalties.
