Following the decision of the Council of the State (2105/2018), which, on the basis of a taxpayer’s request rejected by the tax authority for the transfer of his tax residence, was adopted by the Tax Administration issuing the Circular 1234 / 2018 for the uniform treatment of such tax issues.

The difference between the Taxpayer and the Tax Administration concerning the transfer of the tax residence is annulment.

As a result, a 60-day time limit, application for annulment is filled with the Council of State in accordance with the provisions of Presidential Decree 18/1989 and is not challenged by an in-court appeal.

This concerns only the rejection of an application for transfer of tax residence and not in cases where a tax assessment act is challenged, which it may raise issues of examination of the applicant’s tax domiciliation.