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Insights Update on Tax Audit Framework

Update on Tax Audit Framework

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Effective as of 1 May 2022, an updated tax audit framework will be used when the MIRB performs tax related audit as follows:

  
Significant updates from the new framework refer to voluntary disclosure as well as to the penalties and offences.
  
  • New penalty rate will be imposed, replacing the previous framework rate:

  • Only taxpayers who furnished their tax returns are being offered voluntary disclosure. The penalty rate is at 15 %. If the taxpayers subsequently make an additional voluntary disclosure within 6 months from the date of submission of the tax return, the penalty for the additional voluntary disclosure is at 10 %.
  • In case of tax fraud, the penalty imposed will be at 100 % of underpaid tax.
  • Any technical adjustment that involves different interpretation of tax legislation based on facts and issues of the individual case will not be penalized. However, if there are Public Rulings, Guidelines, Practice Notes, Regulations or Tax Orders Income (Exemption), the technical adjustment grounds will not be applicable. 

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