Here is the translation:
1. Subject of Dispute: Challenging a tax notification-decision on imposing a penalty for late registration of tax invoices.
2. Key Court Arguments:
– The Supreme Court essentially changed previous practice regarding penalty sanctions for late registration of tax invoices.
– The period from March 2020 to May 2022 had a moratorium on penalty sanctions due to quarantine
– Legislation did not create clear conditions for taxpayers regarding invoice registration
– The rule of law principle requires an equal approach to all taxpayers
– It is necessary to consider the taxpayer’s ability to fulfill their obligations
3. Court Decision: Cancel previous court decisions and refer the case for a new review to thoroughly examine the circumstances.
Key Thesis: The court essentially sided with the taxpayer, pointing out the unfairness of the existing penalty mechanism.
