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Through the addition of the 27th Transitory Article to the current Miscellaneous Tax Resolution, specific rules are set out to allow taxpayers who initiated tax interest guarantee proceedings between 1 January and 10 April 2026 to opt into the new flexible regime introduced by the amendment to Article 141 of the Federal Tax Code. The Resolution distinguishes between two scenarios: taxpayers who have not yet received a favourable decision regarding the guarantee offered, and those who already have a previously established guarantee.
In both cases, a written request must be submitted to the competent Decentralised Tax Collection Administration within 30 calendar days of the Decree’s entry into force, with the tax authority having a maximum of 20 business days to issue a ruling. It is worth noting that the replacement of previously established guarantees will not interrupt the stay of the administrative enforcement proceedings, nor will it give rise to additional requirements on the part of the tax authority.
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