- Reopening tax proceedings is only allowed with clearly established new facts or evidence.
- Without a comprehensible justification or sufficient factual findings, reopening is unlawful and must be annulled.
- If the reopening order is annulled, any subsequent substantive decision lacks legal basis.
- The tax authority is bound by the annulment decision and cannot later correct deficiencies in reasoning.
Source: leitnerleitner.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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