Client Alerts

New internal CARF Regulations approved by Ministry of Finance

December 28th, 2023

On December 22, 2023, the Ministry of Finance published Ordinance No. 1,634, which approved the new Internal Proceeding Regulations of the Administrative Council of Tax Appeals (“RICARF”), introducing innovations to the administrative court.

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The new RICARF will come into force on January 05, 2024.

The appeals allocated to each judge before the effectiveness of the new regulations will not be returned or reallocated and must be judged in each respective panel.

MAIN AMENDMENTS

RICARF 2015	NEW RICARF
Maximum terms of 6 years, while judges that serve as chamber or panel President or Vice-President can remain in office for up to 8 years.	Maximum terms of 8 years, while judges that serve as chamber or panel President or Vice-President can remain in office for up to 12 years.
Extraordinary panels would preferentially decide on proceedings that involved a maximum of 60 minimum wages.	Extraordinary panels will preferentially decide on proceedings that involve a maximum of 2,000 minimum wages.
Exclusively synchronous (in person or online) sessions (except extraordinary panels).	Synchronous (in-person, online or hybrid) or asynchronous sessions (Virtual Plenary, with reports and votes submitted through an electronic system that has been approved and regulated by the President of the CARF).
Approval of precedents concentrated in the Full Court of the Higher Chamber of Tax Appeals, with annual convocation.	Precedents can be approved by the Full Court or by the panels of the Higher Chamber of Tax Appeals (direct approval in the session trial, with a simplified and fast procedure).