What is a contradictory assessment of additional tax?

The contradictory assessment of additional tax procedure is applied in all cases where the taxpayer is in conformity with his declaration obligations. The main features of this procedure are a debate between the taxpayer and the tax authorities: proposition of tax adjustments, faculty for the taxpayer to present his observations, and obligation for the tax authority to inform the taxpayer of the action to be taken.


I. The taxpayer may be assisted by an adviser when disscussing the proposed tax adjstusments.

II. The proposed tax adjustments must be fully explained so that the taxpayer has full knowledge of the facts when presenting his arguments and his eventual agreeement. Lack of explanation may invalidate the procedure.

III. The taxpayer has the right to appeal to the controller’s superior (principal or division inspector and area interlocutor) and to request the intervention of the direct incomes and value added tax comission.

IV. The tax authority bears the burden of proof.