Deregulation

How it was?

Doubts were resolved in favour of taxpayers only when tax laws were unclear.

The principle of resolving doubts in favour of the taxpayer applied exclusively to ambiguities in tax legislation. Uncertainties relating to the facts of a case could result in decisions unfavourable to the taxpayer, even when those facts could not be conclusively established.

 

What has changed?

Taxpayers now benefit from the same protection when factual circumstances cannot be conclusively determined.

The new regulations extend the principle of resolving doubts in favour of the taxpayer to factual circumstances as well. If, after the completion of proceedings, not all facts and circumstances of a case can be established with certainty, any remaining doubts should be resolved in favour of the taxpayer.

 

Who benefits?

27 tax decisions applied the principle of resolving doubts in favour of the taxpayer in 2025.

According to 2025 data, tax authorities invoked the principle of resolving doubts in favour of the taxpayer in 27 decisions. This included 22 decisions issued by heads of tax offices at first instance and 5 decisions issued by directors of tax administration chambers at second instance. These figures demonstrate the practical application of taxpayer safeguards within the tax administration system.