Background

The tax authority estimated the value of tax for a company and they objected to these estimates. The case was then referred to the commission of tax appeal which decided the employee who received bonuses for his work abroad should not be subject to income tax on salary.

The tax authority filed a case in order to appeal this decision.

The court upheld the decision of the commission of tax appeal.

The tax authority appealed the ruling before the court of appeal. The court upheld the appealed ruling.

Decision

The tax authority appealed the ruling before the court of cassation and said in its grounds of appeal that the ruling had erred in the application of law and that the court had ignored that the company was a public one and the salaries it pays to employees should be taxed under the relevant laws.