The Maldives Inland Revenue Authority (MIRA) has issued a new tax ruling outlining the procedures for redetermining previously assessed tax amounts in cases where a decision by the Tax Appeal Tribunal or a court judgment mandates a review.
The ruling, identified as TR-2025/A19, establishes procedural guidelines under Section 39 of the Tax Administration Act and Section 21 of the Business Profit Tax Act, ensuring compliance with established regulations. It clarifies that MIRA must follow the prescribed steps in these laws when reassessing tax amounts following legal determinations.
A key provision states that if the Tax Appeal Tribunal or a court directs MIRA to redetermine a tax amount, it will be deemed that the taxpayer was notified of an audit or inquiry on the date of the tribunal’s decision or the court’s judgment. This notification rule also applies when higher courts uphold prior rulings requiring tax reassessments.
Furthermore, any stay orders issued by higher courts pausing a tax redetermination process will suspend the time limits prescribed under the Tax Administration Act and the Business Profit Tax Act until the stay is lifted. Cases under review will be closed if the High Court or Supreme Court overturns a Tax Appeal Tribunal decision requiring MIRA to redetermine a tax amount.
MIRA retains the right to use all relevant information, accounts, and documents collected during prior audits or objections when conducting the redetermination process. The ruling comes into effect from its date of publication in the Government Gazette.
