Tax Objections and Appeals

Statutory Regime
Any person who disagreed any tax assessment made against him/her may challenge it through the
objection and appeal process.1
A taxpayer may object to the tax assessment within one month of the date of the notice of assessment by
writing to the Commissioner stating precisely the grounds of objection. 2 The Commissioner must consider
the objection.3
If the Commissioner agrees with the taxpayer which means that he has validly objected to the assessment,
adjustment of the assessment will be made to the assessment. 4 If the Commissioner disagreed with the
taxpayer, the Commissioner will give a written determination to the taxpayer and the taxpayer may appeal
from that determination to the Board of Review. 5
Appeal to the Board of Review
Where the taxpayer disagreed the determination of the Commissioner, he(referred to as the appellant) may
appeal further by giving notice to appeal to the Board. 6 Unless the appellant or the Commissioner desires
the appeal to be ?leapfrogged? to the Court of First Instance, the hearing and disposal of an appeal to the
Board will be proceeded accordingly. 7
The onus of proving that the assessment appealed against is excessive or incorrect is rested on the
taxpayer.8 After hearing the appeal, the Board shall confirm, reduce, increase or annul the assessment
appealed against or may remit the case to the Commissioner with its opinion on it. 9
The decision of the Board shall be final unless either the appellant or the Commissioner make an
application requiring the Board to state a case on a question of law for the opinion of the Court of First
Instance.10 If such application is made, it must be made in writing and delivered to the clerk to the Board,
together with a prescribed fee11 within 1 month of the date of the Board?s decision. 12
1. Part XI Objections and Appeals of the IRO
2. Section 64(1) IRO
3. Section 64(2)
4. Section 64(3)
5. Section 64(4)
6. Section 66(1)
7. Section 68
8. Section 68(4)
9. Section 68(8)(a)

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