When can they be submitted?

They can be filed within a period of 10 days from the day after reception of the notification.

Who can present a counter-allegation?

  • The person liable for tax;
  • The beneficiaries;
  • The officially designated agent (form to delegate agent);
  • The subsidiary or jointly responsible person.


Time limit for resolutions

This is an official procedure and the allegations should be resolved:

  • If the allegation is denied, in the decision on derivation of responsibility.
  • If the allegation is accepted, in an independent resolution which must be notified to the appellant.