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Costa Rican Court Holds Requirement to Pay Tax before Challenging an Adjustment is Unconstitutional

06 September 2016

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Approved Changes

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Costa Rica

The Constitutional Court of Costa Rica issued a decision on 31 August 2016 concerning the requirement that taxpayers pay or guarantee the amount of tax due resulting from an audit adjustment before the adjustment may be challenged. According to the Court, the requirement is unconstitutional and may no longer be applied by the tax administration as a precondition for a taxpayer's challenge of an assessment.