New Directive Clarifies Procedures for Comprehensive and Partial Accounting Audits
The General Tax Directorate has enacted a new procedure to enhance the transparency of tax control, mandating that inspectors formally notify taxpayers of field audit results—even when no tax corrections are required. Instituted under the 2025 Finance Law, this measure provides an additional legal safeguard, formally closing audit files and eliminating ambiguity following tax investigations.
According to Directive No. 68, issued on October 27 by the Tax Control and Investigations Division, all clarifications regarding field tax control, arbitration requests, and the duty to notify in the absence of corrections have been detailed. The directive, reviewed by Echorouk, was circulated to the Directorate of Large Enterprises, regional tax directors, and heads of investigation services.
This move strengthens guarantees for taxpayers undergoing either a comprehensive or partial accounting audit. It specifically clarifies the procedures for requesting arbitration and obliges inspectors to inform taxpayers of control outcomes regardless of whether adjustments are made.
Under Article 20-6 of the Tax Procedures Law, the right to request arbitration is a key guarantee for taxpayers in a comprehensive audit. This request can be submitted as part of the response to the initial notice of corrections to discuss any factual or legal matter.
A recent amendment to this article further reinforces taxpayer rights, allowing an audit subject to submit an arbitration request in separate correspondence within the legal timeframe for responding to the initial notice. This right is also extended to those undergoing a partial accounting audit under Article 20 bis – 2.
For cases where no corrections are made, Articles 20-8 and 20 bis-6 apply. Article 90 of the 2025 Finance Law clarifies that upon completing a comprehensive audit with no violations, the inspector must notify the taxpayer of the results within the legal period.
This mandatory notification must be delivered via registered mail with acknowledgment of receipt or by hand against a signed receipt. Its purpose is to formally inform the taxpayer that the audit has concluded without any tax adjustments.
To ensure consistency, Article 91 of the 2025 Finance Law introduced a new paragraph (Paragraph 6) to Article 20 bis, stipulating the same notification procedure for partial audits in the absence of corrections, mirroring the provisions for comprehensive audits.
These provisions were previously housed in Article 42 of the same law, which was repealed under Article 95 of the 2025 Finance Law.
It is worth noting that the procedures for both comprehensive and partial accounting audits were detailed in Directive No. 12 dated September 14, 2025, which is recommended for further reference.
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