Tax Procedures: Assessment, Audit, Objections and Appeals
This domain tests the lifecycle of a tax case: self-assessment, tax office audit, issuance of an assessment notice (برگ تشخیص), administrative objection, and litigation before the Dispute Resolution Boards (هیئتهای حل اختلاف مالیاتی).
Core rules
- Taxpayers self-assess and file returns. The tax office may audit books, records, invoices and third-party data, then issue an assessment for additional tax and penalties.
- The taxpayer generally has 30 days from service of the assessment notice to object in writing to the tax office under Article 238. The office reviews the objection and may adjust or confirm the assessment.
- If the objection is rejected, the case is referred to the first-instance Dispute Resolution Board (هیئت بدوی). Its decision can be appealed to the second-instance Board (هیئت تجدیدنظر) within the statutory period.
- Boards examine evidence, hear the taxpayer and the tax office, and may order expert review. They are not limited to the taxpayer’s initial grounds but must observe legal procedures.
- Judicial review by the Administrative Justice Court (دیوان عدالت اداری) is generally available for procedural or legal violations, not for a fresh review of factual merits.
Worked example
A company is served with an assessment on 15 Farvardin. The 30-day objection period ends on 14 Ordibehesht. It files an objection with ledgers and purchase invoices. The office confirms the assessment, so the case goes to the first-instance Board. The Board accepts 40% of the challenged amount because the company proves those purchases. The tax office appeals the remaining 60% to the second-instance Board.
Traps
Missing the 30-day objection is fatal; objecting to the wrong authority delays the case; ignoring service rules can invalidate a hearing; and asking the Administrative Justice Court to re-weigh evidence usually fails.