Post by account_disabled on Nov 6, 2023 23:44:57 GMT -6
He is not at risk of penalties from the tax office - in the event of a change, expiry or repeal of the interpretation and if it is not taken into account in the tax decision by the tax office. Therefore, if a taxpayer acts in accordance with the position recognized as correct in the issued interpretation, it should not harm him, even if this interpretation later turns out to be incorrect. We can read such an explanation, for example, in the judgment of the Provincial Administrative Court in Krakow, reference number.
As a rule, compliance by a given entity with an interpretation known to it, i.e. acting in accordance with its content, does not should harm him, even if this interpretation later turned out to be wrong. Pursuant to the Tax Ordinance, if the interpretation changes, no proceedings philippines photo editor shall be initiated against the entity that applied the interpretation in the previous wording in its proceedings in cases involving fiscal offenses or fiscal offences, proceedings already initiated shall be discontinued and no default interest shall be charged. However, the interpretation is binding in the presented facts. The taxpayer is not protected if the facts differ from reality. Its verification is possible during a tax audit or fiscal audit, and then during tax proceedings.
If the actual situation does not match that described in the application, the taxpayer bears all negative consequences. … ”. Attention! Individual interpretations are issued for a specific person and the individual facts presented to him. Hence, the interpretation only protects the person for whom it was issued. Of course, compliance with an individual tax interpretation will only fulfill a protective function to the extent of the facts indicated in the interpretation. If the actual facts are different than those described in the application.
As a rule, compliance by a given entity with an interpretation known to it, i.e. acting in accordance with its content, does not should harm him, even if this interpretation later turned out to be wrong. Pursuant to the Tax Ordinance, if the interpretation changes, no proceedings philippines photo editor shall be initiated against the entity that applied the interpretation in the previous wording in its proceedings in cases involving fiscal offenses or fiscal offences, proceedings already initiated shall be discontinued and no default interest shall be charged. However, the interpretation is binding in the presented facts. The taxpayer is not protected if the facts differ from reality. Its verification is possible during a tax audit or fiscal audit, and then during tax proceedings.
If the actual situation does not match that described in the application, the taxpayer bears all negative consequences. … ”. Attention! Individual interpretations are issued for a specific person and the individual facts presented to him. Hence, the interpretation only protects the person for whom it was issued. Of course, compliance with an individual tax interpretation will only fulfill a protective function to the extent of the facts indicated in the interpretation. If the actual facts are different than those described in the application.