Taxpayers have a legal right to challenge tax decisions and assessments made by the revenue authority through a structured dispute resolution hierarchy.
+--------------------------------------------------------+
| 1. Notice of Objection |
| Filed by taxpayer within 30 days of assessment. |
+---------------------------+----------------------------+
|
v
+--------------------------------------------------------+
| 2. Alternative Dispute Resolution (ADR) |
| Optional 90-day mediation window to settle out of court|
+---------------------------+----------------------------+
|
v
+--------------------------------------------------------+
| 3. Tax Appeals Tribunal (TAT) |
| Independent body hearing formal tax appeals. |
+---------------------------+----------------------------+
|
v
+--------------------------------------------------------+
| 4. High Court / Court of Appeal |
| Final judicial appeals strictly on matters of law. |
+--------------------------------------------------------+
Notice of Objection
If a taxpayer disagrees with an assessment issued by the Commissioner, they must lodge a formal Notice of Objection within 30 days of receiving the assessment notice. To be considered validly lodged, the objection must clearly state the precise grounds of objection, be supported by all relevant documentary evidence, and the taxpayer must have paid any undisputed tax portion.
The Objection Decision
Upon reviewing the objection, the Commissioner has a statutory period (typically 60 days) to issue an Objection Decision. The Commissioner can choose to allow the objection in whole or in part, or disallow it entirely, providing detailed legal and factual reasons.
Alternative Dispute Resolution (ADR)
To avoid lengthy and costly court battles, the TPA allows taxpayers and the revenue authority to enter into a voluntary ADR mediation framework. The ADR process is strictly timed (usually capped at 90 days). If a mutual agreement is reached, an ADR agreement is signed, and it becomes binding on both parties.
The Tax Appeals Tribunal (TAT)
If ADR fails or if the taxpayer is dissatisfied with the Commissioner’s Objection Decision, they can appeal to the Tax Appeals Tribunal (TAT)—an independent administrative court specializing in tax matters. The taxpayer must file the appeal within 30 days of receiving the Objection Decision.
Â