Assessment-to-Appeal Timelines in Corporate Tax Disputes

Abstract

This study examines the procedural timelines and suspensive effects governing the transition from tax assessment to appeal in Indonesia, the United States, and France. Increasing complexity in tax dispute systems has raised concerns regarding taxpayer access to judicial review and financial exposure during litigation.This study aims to analyze how different procedural designs influence dispute accessibility, liquidity pressure, and interest accumulation. A qualitative comparative legal approach is employed using doctrinal analysis of statutory frameworks, administrative guidelines, and judicial procedures across the three jurisdictions (Thuronyi, 2020).The findings reveal significant institutional variation. Indonesia applies a non-suspensive regime requiring prepayment prior to appeal, thereby increasing liquidity pressure and financial risk. The United States provides automatic suspensive protection through Tax Court procedures, reducing financial burden and enhancing access to dispute resolution. France adopts a conditional model, where suspension is granted upon provision of financial guarantees.These differences demonstrate that procedural design plays a critical role in shaping taxpayer rights, financial risk allocation, and legal certainty. The study concludes that structured suspensive mechanisms and clear procedural safeguards can improve fairness while maintaining effective tax administration (OECD, 2019).