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The amendment eliminates the requirement for taxpayers to demonstrate their financial capacity in order to justify the selection of a guarantee mechanism other than the deposit certificate, instead recognising the right to freely choose from a flexible set of options with no mandatory order of preference. This aims to strengthen legal certainty and reduce the scope for discretion on the part of the tax authority.
In addition, the Decree establishes a transitional regime allowing taxpayers whose guarantee proceedings were initiated between 1 January 2026 and the effective date of the amendment to opt into the new regime, provided they expressly request this within 30 calendar days.
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