Ministry of Revenues

Integrated Tax
Administration System
(ITAS)
Business and Functional
Requirement for Tax Litigation

July 2021

i|Page
Document Control

VERSION HISTORY

Version # Date Revised By Reason for change

1.0 November-2020 BPT Team Detail specification

1.1 November-2020 TTO Leadership Review inputs

1,2 December-2020 IMF Team Provide inputs

1.3 December-2020 Data/IT Team Provide inputs

2.0 February-2021 BPT Team Revised as per IMF and Data/IT comments

3.0 March-2021 BPT Team Revised as per WSTs comments

4.0 April-2021 TTO Team Revised as per feedback from regions and city
administration process harmonization

5.0 June-2021 TTO Team Revised as per internal alignment comments

6.0 July-2021 TTO Team Revised as per IMF quality check feedback

DOCUMENT APPROVALS

Approver Name Role Signature Date

Abere Asfaw Director, Legal Services Directorate

ii | P a g e
Table of Content
Table of Content......................................................................................................................... i
Part I. Introduction.................................................................................................................. 1
1.1. Background and Context............................................................................................................................1
1.2. Purpose of the Document...........................................................................................................................2
Part II. Business and Functional Requirements for Tax Litigation Core Process..............2
2.1. Business Requirement.......................................................................................................................................2
2.2. Functional Requirement....................................................................................................................................4
2.2.1. Electronic Tax Appeal to Tax Appeal Commission.....................................................................5
2.2.1.1. Prepare Hearing Between TP, Lawyer and TAC..........................................................................8
2.2.1.2. Prepare Draft Defense Statement to Appeal Cases.......................................................................9
2.2.1.3. Request to Extend Due Date.......................................................................................................10
2.2.1.4. Review Tax Appeal Decision Letter...........................................................................................11
2.2.2. Electronic Tax Litigation to High Court.....................................................................................12
2.2.2.1. Prepare Draft Defense Statement to Appeal Cases.....................................................................14
2.2.2.2. Review High Court Decision Letter............................................................................................15
2.2.3. Electronic Tax Litigation to Supreme Court...............................................................................17
2.2.3.1. Prepare Draft Defense Statement to Appeal Cases.....................................................................19
2.2.3.2. Review Supreme Court Decision Letter.....................................................................................20
2.2.4. Electronic Tax Litigation to Cassation Bench............................................................................21
2.2.4.1. Prepare Draft Defense Statement to Cassation Bench Cases......................................................23
2.2.5. Respond to Request of Execution...............................................................................................24
2.2.5.1. Prepare Draft Defense Statement................................................................................................25
2.2.5.2. Review Court Order....................................................................................................................26
2.2.6. Data Analytics on Tax Litigation Cases.....................................................................................28
2.2.7. Directive Drafting.......................................................................................................................30
2.2.8. Legal Advice and Training.........................................................................................................31
2.2.9. Legal Training.............................................................................................................................32
2.2.10. Civil Cases Litigation..................................................................................................................33
3. Annexures.......................................................................................................................... 33
Annex 1. List of Acronyms....................................................................................................................................33
Annex 2. Requirement Prioritization Convention.................................................................................................34
Annex 3. Glossary of Terms..................................................................................................................................34
Annex 4. Related Reference Documents...............................................................................................................34

iii | P a g e
Part I. Introduction
1.1. Background and Context

Ministry of Revenues has developed its ten-year strategic plan (from 2013 - 2022 Ethiopian
Calendar) with a vision to build a modern tax administration which enables the country to
cover its expenditures from tax and customs income. Realizing that the current state of
operational capability is not adequate to meet realize its vision and achieve its strategic goals,
the ministry launched a five-year tax transformation programme, identifying key priority areas
of reform. Business Process Transformation (BPT) is one of the six priority areas that the tax
transformation programme will be implementing during this period. This BPT is intended to
bring about operational excellence and organizational efficiency to deliver the mission given to
the ministry i.e., increasing revenue collections, customer satisfaction, voluntary compliance,
digitalization and other performance perspectives. Without such transformation initiatives,
MoR cannot keep abreast of global developments and support the nation’s economy to the
expected level.

In depth analysis of the Ministry’s current processes revealed the following major gaps:

 High level of manual processing;

 High compliance costs for taxpayers;
 Lack of integration and data sharing;
 Increased cost of collection and enforcement to the Ministry;
 Lack of standardized list of required process input documents;
 Technology and infrastructure limitations;
 Limited role of risk management;
 Static risk model;
 Lack of Automated Document Management and Case Management Systems;
 Limited Focus and Scope for Taxpayer Education;
 Lack of Coordination and Communication;
 Lack of adequate human capacity

1|Page
In order to realize the ambitious vision and alleviate the challenges in its current processes,
the Ministry decided to undergo massive business process transformation across its core and
enforcement processes. Besides, based on the revised business process, the Ministry
decided to implement an integrated tax administration system (ITAS) and related technologies.
Currently, future state (To-Be) business processes are mapped for the domestic tax 12 core
processes using Business Process Modeling and Notation (BPMN V2.0) methodology and
Bizagi modeling tool. To harmonize business processes and business/functional requirement
for federal, regions and city administrations, the Ministry organized a one-week harmonization
workshop. Hence, this document is prepared to elicit business and functional requirements of
the Ministry (including federal, regions and city administrations) based on approved future
state (To-be) business process maps and formally document the requirements for further use.

1.2. Purpose of the Document

This document defines the high level business requirements and detailed functional
requirements of Integrated Tax Administration System (ITAS) project. The document will be
used as basis for the following activities:

 Creating request(s) for proposal (RfP) – in particular for a planned new Integrated
Tax Administration System (ITAS) bit also for other components of MOR’s
modernization such as an e-invoicing solution, and Data Warehouse / BI solution;
 Creating solution designs;
 Developing Standard Operating Procedures for MoR officers;
 Developing test plans, test scripts, and test cases;
 Assessing project success in terms of meeting client requirements;

Part II. Business and Functional Requirements for Tax Litigation

Core Process

2|Page
2.1. Business Requirement
MoR needs to have a Tax Litigation process. The Tax Litigation process involves receiving
taxpayer appeals against tax assessments and review the case in an independent manner.
The Tax Litigation process can be carried out manually or automated. The Tax Litigation
business process would include:

A. Tax Litigation to Tax Appeal Commission / High Court / Supreme Court

 Enhancing transparency on the tax litigation process and subsequent decisions

 Automated documentation of tax litigation cases for future reference and build
knowledge base
 System supported and quick access to documents received from taxpayers and
audit team
 Case management system for tax litigation process which will allow MoR/ Regional
Revenue Administrations to record their step by step actions on a tax litigation case
and the actions by the taxpayer so that the tax litigation system would function
efficiently and effectively through system alerts for action on tax litigation cases
 Standardized and transparent tax litigation process as per appropriate
disclosure policy
 Improve performance of the tax litigation team
 Enhanced performance management by automatically generating KPI from
case management system
 Improving quality of decisions
 Other business requirements:
 Ability to record and track hearing arguments and decisions
 Ability to enter, maintain and update determinations per appropriate business
rules.
 Ability to display and print a Certified Copy of the decisions..
 Ability to display comparative information related to appealed assessments: as
assessed, as determined by TAC, and ultimate determination (by court).
 Ability to indicate situations where multiple parties are liable and all have
appealed.

3|Page
  Ability to indicate situations where multiple parties are liable and only one party
has appealed (e.g., personal liability, predecessor/successor or choice of
employer).
 Ability to export Final Determinations for intranet and/or Internet publication.

B. Data Analytics on Tax Litigation Cases

 Provide advanced data analytics capability to create complex and cross cutting reports.
 Provide standard reports on cases received, cases resolved, value of disputed cases
per sector/segment/tax types, nature of issues per sector/segments/tax type to enable
MoR to analyse Impact of Tax Litigation Case on the Policy/ Legal/ Operational and
Create Recommendation

2.2. Functional Requirement

This section presents the To-Be business process map for all sub processes under the tax appeal core
process and details of functional requirements aligned with the future state (To-Be) sub process maps:

4|Page
2.2.1. Electronic Tax Appeal to Tax Appeal Commission

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.1.2-01 The system shall be able to calculate the deposit that M Under current
needs to be paid by taxpayer prior to submission of Tax legislation, taxpayer
Appeal to the Tax Appeal Commission. The Deposit must pay 50% deposit
amount shall be configurable to reflect the latest rules and before submitting an
regulations. appeal to Tax Appeal
Commission.
FR-07.1.2-02 The system shall be able to validate payment of deposit M
and issue a receipt. This receipt shall be given by
taxpayer to Tax Appeal Commission as a prerequisite for
appeal in Tax Appeal Commission.
FR-07.1.2-03 The system shall enable taxpayer to submit tax appeal M Case Management

5|Page
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
request and upload the supporting documents. The
system shall be able to check the due date of appeal. If
appeal have already passed the due date, the system
shall automatically rejected the tax appeal request. The
system shall enable taxpayer to request extension of due
date to Tax Appeal Commission. The process FR-07.1.2.3
Request to Extend Due Date shall be started.

The system shall treat each Tax Appeal submitted request

as a case flow management with various steps,
delegations, responsible persons, decisions,
approvals/rejections, notifications and others. The system
shall allow capturing of detailed information of each step
using appropriate screens.
FR-07.1.2-04 The system shall record the request and its supporting M
documents in the database then alert Tax Appeal
Commission, Legal Department and related units of new
Tax Appeal Case.
FR-07.1.2-05 The system shall provide an interface for Tax Appeal M
Commission to view case documents from the system.
FR-07.1.2-06 The system shall provide the necessary documents M The list of related
needed for Tax Appeal Commission to review the case. information that should
The system shall provide an interface to access all related be available for
data on taxpayer in the data warehouse (including but not viewing by Tax Appeal
limited to Audit Working Papers, Taxpayer information, Commission should be
Taxpayer historical records) identified during the
requirement validation
stage.
FR-07.1.2-07 If the Tax Appeal Commission requires more supporting M
documents from taxpayer to supplement the Tax Appeal
Commission when reviewing the case, the system shall
send an alert to taxpayer that more documents are
needed.
Taxpayer must upload the additional documents within
the configurable time frame.
FR-07.1.2-08 The system shall provide an interface for taxpayer to M The list of supporting
upload the additional supporting document specified by documents required
Tax Appeal Commission then restart the FR-07.1.2-05 should be
process. configurable.
FR-07.1.2-09 If the Tax Appeal Commission reject the case, the system M
shall enable Tax Appeal Commission to send rejection
letter to taxpayer and the MoR explaining reasons of
rejection for both parties.
FR-07.1.2-10 If the Tax Appeal Commission accept the case, the M
system shall enable Tax Appeal Commission to send
letter to MoR Team Leader/ Process Owner/ Legal
Director requesting for Statement of Defense.
FR-07.1.2-11 The system shall enable Team Leader/ Process Owner/ M
Legal Director to assign Lawyers for the Tax Appeal
Case.
FR-07.1.2-12 MoR Lawyer shall prepare Draft Defense Statement to M
Tax Appeal Cases. The system shall start FR-07.1.2.2
process.
FR-07.1.2-13 If MoR Lawyer requires more information from Tax M
Officer/ Tax Auditor, the system shall prompt the Lawyer

6|Page
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
to make a request and then alert Tax Officer/ Tax Auditor
of MoR Lawyer request.
FR-07.1.2-14 The system shall provide an interface for Tax Officer/ Tax M
Auditor to review the request from MoR Lawyer and
upload the supporting document / information as
requested by MoR Lawyer.
FR-07.1.2-15 If MoR Lawyer finishes drafting the Defense Statement, M
the system shall allow the Lawyer to capture the
statement and then alert Team Leader/ Process Owner/
Legal Director requesting approval of Defense Statement.
FR-07.1.2-16 The system shall provide interface for Team Leader/ M
Process Owner/ Legal Director to review and evaluate the
draft Defense Statement. If Team Leader/ Process
Owner/ Legal Director approves the Draft Defense
Statement, the system shall send the Digitally Signed
Defense Statement to Tax Appeal Commission. If Team
Leader/ Process Owner/ Legal Director disapproves the
Defense Statement, the system shall alert the MoR
Lawyer to restart the FR-07.1.2-12 process noting the
recommendation for improvement from Team Leader/
Process Owner/ Legal Director.
FR-07.1.2-17 After the Tax Appeal Commission accepts the Defense M
Statement from MoR Team Leader/ Process Owner/
Legal Director, the system shall enable Tax Appeal
Commission to prepare for the hearing by analyzing the
Tax Appeal cases based on the objection, Defense
Statement and the Tax Audit results.
FR-07.1.2-18 The system shall activate the FR-07.1.2.1 Prepare M
Discussion between Taxpayer, MoR Lawyer, Tax Auditor/
Tax Officer and Tax Appeal Commission sub process.
FR-07.1.2-19 The system shall enable Tax Appeal Commission to store M
the result of multiple discussions / hearing between
Taxpayer, MoR Lawyer, Tax Appeal Commission and or
Tax Officer/ Tax Auditor.
FR-07.1.2-20 Tax Appeal Commission shall review the findings and M
identify list of adjustments needed. The system shall
enable Tax Appeal Commission to capture the
recommendation in the system and the system shall
notify/alert the Team Leader/ Process Owner/ Legal
Director of the Tax Appeal Decision Letter.
FR-07.1.2-21 The system shall activate the FR-07.1.2.4 Review Tax M
Appeal Decision Letter. If Team Leader/ Process Owner/
Legal Director decides to appeal to the High Court, the
process FR-07.2-01 Appeal to the High Court will start.
FR-07.1.2-22 If Team Leader/ Process Owner/ Legal Director decides to M
not appeal, The system shall enable Team Leader/
Process Owner/ Legal Director to forward the Tax Appeal
Decision Letter to MoR Lawyer and Tax Auditor/Officer.
FR-07.1.2-23 The Tax Auditor would prepare Draft Revised Notice of M
Assessment based on Tax Appeal Commission decision
using system’s functionality. The system shall send the
draft Revised Notice of Assessment to Tax Auditor’s
Manager for approval. It is in-line with Revised Returns
part of the Filing and Refund Process. All necessary
requirements such as approving of revised assessment,

7|Page
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
notifications, updating ledger and others are equally
applied here.
FR-07.1.2-24 If Tax Auditor’s Manager sees non-conformity in the M
Revised Notice of Assessment, the system shall send a
notification to the corresponding Tax Auditor/ Tax Officer
noting the details of non-conformity in the Revised Notice
of Assessment. Activity FR-07.1.2-23 would restart.
FR-07.1.2-25 When Tax Auditor’s Manager finds the Revised Notice of M
Assessment is consistent with the Tax Appeal
Commission’s Decision letter, he/she approves the
Revised Notice of Assessment electronically and the
system shall send the Revised Notice of Assessment to
taxpayer.
FR-07.1.2-26 After receiving Tax Appeal Decision Letter (TADL), the M
system shall enable taxpayer to request Tax Appeal
Commission to review the judgment for minor clerical
error. Upon receiving this request, Tax Appeal
Commission would restart the FR-07.1.2-20 activities.
If no changes in TADL is needed then the process should
stop.

2.2.1.1. Prepare Hearing Between TP, Lawyer and TAC

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.1.2.1-01 The system shall enable Tax Appeal Commission (TAC) M
to collect all supporting documentation to be used for

8|Page
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
discussion internal Tax Appeal Commission.
FR-07.1.2.1-02 Upon discussion with Tax Appeal Commission, the M
system shall enable MoR lawyers to revise the defense
statement and send it to Legal Director for approval.

Upon receiving the revised defense statement, the system

shall enable Legal Director to review the revised defense
statement. Upon approval by Legal Director, the system
shall automatically send the revised defense statement to
Tax Appeal Commission.
FR-07.1.2.1-03 The system shall enable Tax Appeal Commission to send M
the copy of Defense Statement and hearing date to
taxpayer and Ministry of Revenue.

2.2.1.2. Prepare Draft Defense Statement to Appeal Cases

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.1.2.2-01 The system shall allow MoR Lawyer to review the cases M
by looking at taxpayer information, previous tax audit
result and tax review decision stored in the system.
FR-07.1.2.2-02 The system shall present MoR Lawyer similar appeal M
cases stored by providing historical data on past cases.
FR-07.1.2.2-03 The system shall provide an interface for MoR Lawyer to M
store the draft Defense Statement in the system and send
to Team Leader/ Process Owner/ Legal Director for
approval.

9|Page
2.2.1.3. Request to Extend Due Date

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.1.2.3-01 The system shall enable taxpayer to request extension of M
tax appeal due date to Tax Appeal Commission.
FR-07.1.2.3-02 The system shall enable Tax Appeal Commission to M
review the request.
If Tax Appeal Commission approves the request, the
system shall enable Tax Appeal Commission to extend
the due date for appeal for the specific taxpayer. The
system shall then automatically send notification to
taxpayer, MoR Lawyer and auditor of approved due date
extension.
If Tax Appeal Commission rejects the request, the system
shall automatically send rejection notification noting
reasons of rejection to taxpayer , MoR Lawyer and auditor
.

10 | P a g e
2.2.1.4. Review Tax Appeal Decision Letter

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.1.2.4-01 The system shall enable MoR Lawyer to review the Tax M
Appeal Decision Letter.
If the MoR lawyer decides to appeal, the process of
Appeal to High Court is started.
If the MoR lawyers decide to not appeal then the system
shall enable MoR Lawyer to prepare justification letter on
why not appealing and send to Team Leader for approval.

FR-07.1.2.4-02 The system shall enable Team Leader to review the M

justification letter.
If the Team Leader decides to appeal the process of
Appeal to High Court starts.
If the Team Leader decides to not appeal then the system
shall enable Team Leader to send recommendation letter
to Legal Director on why not appealing.

FR-07.1.2.4-03 The system shall enable Legal Director to review the case
on why not appealing to the next level court.
If Legal Director decides not to appeal then the process

11 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
stop.
If Legal Director decides to appeal to the next higher court
then the process Appeal to High Court shall be activated.

2.2.2. Electronic Tax Litigation to High Court

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.2.2-01 The system shall be able to calculate the deposit that M Under current
needs to be paid by taxpayer prior to submission of Tax legislation, taxpayer
Appeal to High Court. The Deposit amount shall be must pay 75% deposit
configurable to reflect the latest rules and regulations. before submitting an
appeal to High Court. If
taxpayer already paid
50% deposit when
submitting appeal in

12 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
Tax Appeal
Commission, taxpayer
only need to pay the
remaining 25%
deposit-
FR-07.2.2-02 The system shall be able to validate payment of deposit M
and issue a receipt. This receipt shall be given by
taxpayer to High Court as a prerequisite for appeal in
High Court.
FR-07.2.2-03 The system shall provide an interface to enable MoR to M
send specific data to High Court system for Taxpayers
whose cases are to be heard (including but not limited to
Audit Working Papers, Taxpayer information, Taxpayer
historical records).
FR-07.2.2-04 Upon receiving the Hearing Date from High Court, the M
system shall enable Team Leader/ Process Owner/ Legal
Director to register the tax appeal to high court case and
assign Lawyer for the case.
FR-07.2.2-05 The system shall treat each Tax Appeal to high court as a M
case flow management with various steps, delegations,
responsible persons, decisions, approvals/rejections,
notifications and others. For each step, the system shall
allow capturing of detailed information of each step using
appropriate screens.
FR-07.2.2-06 Mor Lawyer shall prepare Draft Defense Statement to Tax M
Appeal to High Court Cases. The system shall start FR-
07.2.2.1 process.
FR-07.2.2-07 If MoR Lawyer requires more information from Tax M
Officer/ Tax Auditor, the system shall alert Tax Officer/
Tax Auditor of MoR Lawyer’s request.
FR-07.2.2-08 The system shall provide an interface for Tax Officer/ Tax M
Auditor to review the request from MoR lawyer and upload
the supporting document / information as requested by
MoR Lawyer.
FR-07.2.2-09 If MoR Lawyer finishes drafting the Defense Statement, M
the system shall alert Team Leader/ Process Owner/
Legal Director requesting approval of Defense Statement.
FR-07.2.2-10 The system shall provide interface for Team Leader/ M
Process Owner/ Legal Director to review and evaluate the
draft Defense Statement. If Team Leader/ Process
Owner/ Legal Director approve the Draft Defense
Statement, the MoR Lawyer send Defense Statement to
High Court. If Team Leader/ Process Owner/ Legal
Director disapprove the Defense Statement, the system
shall alert the MoR Lawyer to restart the FR-07.2.2-06
process noting the recommendation for improvement from
Team Leader/ Process Owner/ Legal Director.
FR-07.2.2-11 The system shall enable MoR Lawyer to store the result of M
multiple High Court hearing between Taxpayer, MoR
Lawyer and High Court.
FR-07.2.2-12 Upon receiving High Court Decision Letter or Revised Tax M
Appeal Decision letter, MoR Team Leader/ Process
Owner/ Legal Director Secretariat shall record the
documents in the system. The process 07.2.2.2 review
high court decision letter shall start. If Team Leader/

13 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
Process Owner/ Legal Director decide to appeal to the
Supreme Court, the process FR-07.3-01 Tax Litigation to
the Supreme Court will start. If Team Leader/ Process
Owner/ Legal Director decide to accept the Decision
Letter by High Court, the system shall send an alert to
MoR Lawyer to forward the High Court decision and the
follow up action to corresponding Tax Auditor/ Tax Officer.
FR-07.2.2-13 The Tax Auditor would prepare Draft Revised Notice of M
Assessment based on High Court decision. The system
shall send the draft Revised Notice of Assessment to Tax
Officer/ Tax Auditor manager for approval.
FR-07.2.2-14 If Tax Officer/ Tax Auditor’s manager see non-conformity M
in the Revised Notice of Assessment, the system shall
send a notification to Tax Auditor/ Tax Officer noting the
non-conformity in the Revised Notice of Assessment.
Activity FR-07.2.2-13 would be restarted.
FR-07.2.2-15 Tax Officer/ Tax Auditor’s manager will review the M
conformity of Revised Notice of Assessment to the High
Court Decision letter. If the Revised Notice of Assessment
conforms the High Court Decision letter, the system shall
send the Revised Notice of Assessment to taxpayer

2.2.2.1. Prepare Draft Defense Statement to Appeal Cases

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.2.2.1-01 The system shall provide an interface for MoR Lawyer to M
examine the cases by looking at taxpayer information,
previous tax audit result and tax review decision stored in

14 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
the system.
FR-07.2.2.1-02 The system shall enable MoR lawyer to do desk research M
on similar appeal cases stored in the data warehouse by
providing historical data on past cases.
FR-07.2.2.1-03 The system shall provide an interface for MoR Lawyer to M
store the draft Defense Statement in the system. MoR
Lawyer need to specify if it required supporting
documents/ explanation from Tax Auditor/ Tax Officer. If
MoR Lawyer does not need further explanation, the
system shall send an alert to Team Leader/ Process
Owner/ Legal Director requesting approval for Draft
Defense Statement. If MoR Lawyer needs further
explanation from Tax Auditor/ Tax Officer, the system
shall send an alert to Tax Auditor/ Tax Officer requesting
for further explanation/ additional supporting documents.

2.2.2.2. Review High Court Decision Letter

15 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
FR-07.2.2.2-01 The system shall enable MoR lawyers to review the High M
Court Decision Letter.
If the MoR lawyers decide to appeal the process of Tax
Litigation to Supreme Court is started.
If the MoR lawyers decide to not appeal then the system
shall enable MoR lawyers to prepare justification letter on
why not appealing and send to Team Leader for approval.

FR-07.2.2.2-02 The system shall enable Team Leader to review the M

justification letter.
If the team leader decide to appeal the process of Tax
Litigation to Supreme Court started.
If the team leader decide to not appeal then the system
shall enable team leader to send recommendation letter
to Legal Director on why not appealing.

FR-07.2.2.2-03 The system shall enable Legal Director to review the case M
on why not appealing to the next level court.
If Legal Director decides not to appeal then the process
stop.
If Legal Director decides to appeal to the next higher court
then the process Tax Litigation to Supreme Court shall be
activated.

16 | P a g e
2.2.3. Electronic Tax Litigation to Supreme Court

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.3.2-01 The system shall provide an interface to enable MoR to M
send specific data to Supreme Court system for
Taxpayers whose cases are to be heard (including but not
limited to Audit Working Papers, Taxpayer information,
Taxpayer historical records, Case Notes from previous
High Court).
FR-07.3.2-02 Upon receiving the Hearing Date from Supreme Court, the M
system shall enable Team Leader/ Process Owner/ Legal
Director to register the tax appeal to Supreme Court case
and assign Lawyers for the case.

17 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
FR-07.3.2-03 The system shall treat each Tax Appeal submitted request M
as a case flow management with various steps,
delegations, responsible persons, decisions,
approvals/rejections, notifications and others. For each
step, the system shall allow capturing of detailed
information of each step using appropriate screens.
FR-07.3.2-04 MoR Lawyer shall prepare Draft Defense Statement to M
Tax Litigation to Supreme Court Cases. The system shall
start FR-07.3.2.1 process.
FR-07.3.2-05 If MoR Lawyer requires more information from Tax M
Officer/ Tax Auditor, the system shall alert Tax Officer/
Tax Auditor of MoR lawyer request.
FR-07.3.2-06 The system shall provide an interface for Tax Officer/ Tax M
Auditor to review the request from MoR Lawyer and
upload the supporting document / information as
requested by MoR lawyer.
FR-07.3.2-07 If MoR Lawyer finishes drafting the Defense Statement, M
the system shall alert Team Leader/ Process Owner/
Legal Director requesting approval of Defense Statement.
FR-07.3.2-08 The system shall provide interface for Team Leader/ M
Process Owner/ Legal Director to review and evaluate the
draft Defense Statement. If Team Leader/ Process
Owner/ Legal Director approve the Draft Defense
Statement, the system shall send the Digitally Signed
Defense Statement to Supreme Court. If Team Leader/
Process Owner/ Legal Director disapprove the Defense
Statement, the system shall alert the MoR Lawyer to
restart the FR-07.3.2-04 process noting the
recommendation for improvement from Team Leader/
Process Owner/ Legal Director.
FR-07.3.2-09 The system shall enable MoR Lawyer to store the result of M
multiple Supreme Court hearing between Taxpayer, MoR
Lawyer and Supreme Court.
FR-07.3.2-10 Upon receiving Supreme Court Decision Letter or revised M
High Court Decision Letter or Revised Tax Appeal
Decision Letter, MoR Team Leader/ Process Owner/
Legal Director Secretariat shall record the documents in
the system and forward them to MoR Lawyer
The process 07.3.2.2 Review Supreme Court Decision
Letter shall be activated.
FR-07.3.2-11 MoR Lawyer shall forward the Supreme Court decision M
and the follow up action to Tax Auditor/ Tax Officer.
FR-07.3.2-12 The Tax Auditor shall prepare Draft Revised Notice of M
Assessment based on Supreme Court decision. The
system shall send the draft Revised Notice of Assessment
to Tax Officer/ Tax Auditor’s manager for approval.
FR-07.3.2-13 If Tax Officer/ Tax Auditor’s manager see non-conformity M
in the Revised Notice of Assessment, the system shall
send a notification to Tax Auditor/ Tax Officer noting the
non-conformity in the Revised Notice of Assessment.
Activity FR-07.3.2-11 would be restarted.
FR-07.3.2-14 Tax Officer/ Tax Auditor’s Manager will review the M
conformity of Revised Notice of Assessment to the
Supreme Court Decision letter. If the Revised Notice of
Assessment conforms the Tax Appeal Decision letter, the

18 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
system shall send the Revised Notice of Assessment to
taxpayer.
FR-07.3.2-15 Upon receiving Revised Notice of Assessment, Taxpayer M
could pay the Taxes as stipulated in the Revised Notice
of Assessment in the system payment interface and the
process stop.

2.2.3.1. Prepare Draft Defense Statement to Appeal Cases

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.3.2.1-01 The system shall enable MoR Lawyer to examine the M
cases by looking at taxpayer information, previous tax
audit result, tax review decision and tax appeal in High
Court decision stored in the system.
FR-07.3.2.1-02 The system shall enable MoR Lawyer to do desk research M
on similar appeal cases stored in the data warehouse by
providing historical data on past cases.
FR-07.3.2.1-03 The system shall provide an interface for MoR Lawyer to M
store the draft Defense Statement in the system. MoR
Lawyer needs to specify if it requires supporting
documents/ explanation from Tax Auditor/ Tax Officer. If
MoR Lawyer does not need further explanation, the
system shall send an alert to Team Leader/ Process
Owner/ Legal Director requesting approval for Draft
Defense Statement. If MoR Lawyer needs further

19 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
explanation from Tax Auditor/ Tax Officer, the system
shall send an alert to Tax Auditor/ Tax Officer requesting
for further explanation/ additional supporting documents.

2.2.3.2. Review Supreme Court Decision Letter

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.3.2.2-01 The system shall enable MoR lawyers to review the M
Supreme Court Decision Letter.
If the MoR lawyers decide to appeal the process of Tax
Litigation to Cassation Bench started.
If the MoR lawyers decide to not appeal then the system
shall enable MoR lawyers to prepare justification letter on
why not appealing and send to Team Leader for approval.

FR-07.3.2.2-02 The system shall enable Team Leader to review the M

justification letter.

20 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
If the team leader decide to appeal the process of Tax
Litigation to Cassation Bench started.
If the team leader decide to not appeal then the system
shall enable team leader to send recommendation letter
to Legal Director on why not appealing.

FR-07.3.2.2-03 The system shall enable Legal Director to review the case
on why not appealing to the next level court.
If Legal Director decides not to appeal then the process
stop.
If Legal Director decides to appeal to the next higher court
then the process Tax Litigation to Cassation Bench shall
be activated.

21 | P a g e
2.2.4. Electronic Tax Litigation to Cassation Bench

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.4.2-01 The system shall provide an interface to enable MoR to M
send specific data to Cassation Bench system for
Taxpayers whose cases are to be heard (including but not
limited to Audit Working Papers, Taxpayer information,
Taxpayer historical records, Case Notes from previous
Court).
FR-07.4.2-02 Upon receiving the Hearing Date from Cassation Court, M
the system shall enable Team Leader/ Process Owner/
Legal Director to register the tax litigation to Cassation
Bench case and assign Lawyers for the case.

22 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
FR-07.4.2-03 The system shall treat each Tax Litigation submitted M
request as a case flow management with various steps,
delegations, responsible persons, decisions,
approvals/rejections, notifications and others. For each
step, the system shall allow capturing of detailed
information of each step using appropriate screens.
FR-07.4.2-04 MoR Lawyer shall prepare Draft Defense Statement to M
Tax Litigation to Cassation Bench Cases. The system
shall start FR-07.4.2.1 process.
FR-07.4.2-05 If MoR Lawyer requires more information from Tax M
Officer/ Tax Auditor, the system shall alert Tax Officer/
Tax Auditor of MoR lawyer request.
FR-07.4.2-06 The system shall provide an interface for Tax Officer/ Tax M
Auditor to review the request from MoR lawyer and upload
the supporting document / information as requested by
MoR Lawyer.
FR-07.4.2-07 If MoR Lawyer finishes drafting the Defense Statement, M
the system shall alert Team Leader/ Process Owner/
Legal Director requesting approval of Defense Statement.
FR-07.4.2-08 The system shall provide interface for Team Leader/ M
Process Owner/ Legal Director to review and evaluate the
draft Defense Statement. If Team Leader/ Process
Owner/ Legal Director approve the Draft Defense
Statement, the system shall send the Digitally Signed
Defense Statement to Cassation Bench. If Team Leader/
Process Owner/ Legal Director disapprove the Defense
Statement, the system shall alert the MoR Lawyer to
restart the FR-07.4.2-04 process noting the
recommendation for improvement from Team Leader/
Process Owner/ Legal Director.
FR-07.4.2-09 The system shall enable MoR Lawyers to store the result M
of multiple Cassation Bench hearing between Taxpayer,
MoR Lawyer and Cassation Bench.
FR-07.4.2-10 Upon receiving Cassation Bench Decision Letter or M
revised Supreme Court Decision Letter or revised High
Court Decision Letter or Revised Tax Appeal Decision
Letter, MoR Team Leader/ Process Owner/ Legal Director
Secretariat shall record the documents in the system and
forward them to MoR Lawyer.
FR-07.4.2-11 Legal Director shall forward the Cassation Bench decision M
and the follow up action to Tax Auditor/ Tax Officer.
FR-07.4.2-12 The Tax Auditor shall prepare Draft Revised Notice of M
Assessment based on Cassation Bench decision. The
system shall send the draft Revised Notice of Assessment
to Tax Officer/ Tax Auditor’s manager for approval.
FR-07.4.2-13 If Tax Officer/ Tax Auditor’s manager see non-conformity M
in the Revised Notice of Assessment, the system shall
send a notification to Tax Auditor/ Tax Officer noting the
non-conformity in the Revised Notice of Assessment.
Activity FR-07.3.2-12 would be restarted.
FR-07.4.2-14 Tax Officer/ Tax Auditor’s manager will review the M
conformity of Revised Notice of Assessment to the
Cassation Bench Decision letter. If the Revised Notice of
Assessment conforms the Cassation Bench Decision
letter, the system shall send the Revised Notice of

23 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
Assessment to taxpayer.
FR-07.4.2-15 Upon receiving Revised Notice of Assessment, Taxpayer M
could pay the Tax Duty as stipulated in the Revised
Notice of Assessment in the system payment interface
and the process stop.

2.2.4.1. Prepare Draft Defense Statement to Cassation Bench Cases

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.4.2.1-01 The system shall enable MoR Lawyer to examine the M
cases by looking at taxpayer information, previous tax
audit result, tax review decision and tax litigation decision
letter from previous level court that is stored in the
system.
FR-07.4.2.1-02 The system shall enable MoR Lawyer to do desk research M
on similar appeal cases stored in the data warehouse by
providing historical data on past cases.
FR-07.4.2.1-03 The system shall provide an interface for MoR lawyer to M
store the draft Defense Statement in the system. MoR
Lawyer needs to specify if it requires supporting
documents/ explanation from Tax Auditor/ Tax Officer. If
MoR Lawyer does not need further explanation, the
system shall send an alert to Team Leader/ Process
Owner/ Legal Director requesting approval for Draft
Defense Statement. If MoR Lawyer needs further
explanation from Tax Auditor/ Tax Officer, the system
shall send an alert to Tax Auditor/ Tax Officer requesting
for further explanation/ additional supporting documents.

24 | P a g e
2.2.5. Respond to Request of Execution

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.6-01 The system shall provide an interface to enable MoR to M
sends specific data to court system for Taxpayers whose
cases are to be heard (including but not limited to Audit
Working Papers, Taxpayer information, Taxpayer
historical records, Case Notes from previous Court).
FR-07.6-02 Upon receiving the Hearing Date from Court, the system M
shall enable Team Leader/ Process Owner/ Legal Director
to register the case and assign Lawyers for the case.
FR-07.6-03 The system shall treat each submitted request as a case M
flow management with various steps, delegations,
responsible persons, decisions, approvals/rejections,
notifications and others. For each step, the system shall
allow capturing of detailed information of each step using
appropriate screens.

25 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
FR-07.6-04 MoR Lawyer shall prepare Draft Defense Statement to the M
Cases. The system shall start FR-07.6.1 Prepare Draft
Defense Statement process.
FR-07.6-05 If MoR Lawyer requires more information from Tax M
Officer/ Tax Auditor, the system shall alert Tax Officer/
Tax Auditor of MoR lawyer request.
FR-07.6-06 The system shall provide an interface for Tax Officer/ Tax M
Auditor to review the request from MoR lawyer and upload
the supporting document / information as requested by
MoR lawyer.
FR-07.6-07 If MoR Lawyer finishes drafting the Defense Statement, M
the system shall alert Team Leader/ Process Owner/
Legal Director requesting approval of Defense Statement.
FR-07.6-08 The system shall provide interface for Team Leader/ M
Process Owner/ Legal Director to review and evaluate the
draft Defense Statement. If Team Leader/ Process
Owner/ Legal Director approve the Draft Defense
Statement, the system shall send the Digitally Signed
Defense Statement to the Court. If Team Leader/ Process
Owner/ Legal Director disapprove the Defense Statement,
the system shall alert the MoR Lawyer to restart the FR-
07.6.2-04 process noting the recommendation for
improvement from Team Leader/ Process Owner/ Legal
Director.
FR-07.6-09 the system shall enable MoR Lawyers to store the result M
of Court hearing between Taxpayer, MoR Lawyer and the
Court.
FR-07.6-10 Upon receiving Court Decision Letter Team Leader/ M
Process Owner/ Legal Director Secretariat shall record
the documents in the system and forward them to MoR
Lawyer. The process 07.6.2 review court order shall be
activated.
FR-07.6-11 Legal Director shall forward the Court Decision and the M
follow up action to Tax Auditor/ Tax Officer.

26 | P a g e
2.2.5.1. Prepare Draft Defense Statement

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.6.1-01 The system shall enable MoR Lawyer to examine the M
cases by looking at taxpayer information, previous tax
audit result, tax review decision and tax litigation decision
stored in the system.
FR-07.6.1-02 The system shall enable MoR Lawyer to do desk research M
on similar tax litigation cases stored in the data
warehouse by providing historical data on past cases.
FR-07.6.1-03 The system shall provide an interface for MoR lawyer to M
store the draft Defense Statement in the system. MoR
Lawyer needs to specify if it requires supporting
documents/ explanation from Tax Auditor/ Tax Officer. If
MoR Lawyer does not need further explanation, the
system shall send an alert to Team Leader/ Process
Owner/ Legal Director requesting approval for Draft
Defense Statement. If MoR Lawyer need further
explanation from Tax Auditor/ Tax Officer, the system
shall send an alert to Tax Auditor/ Tax Officer requesting
for further explanation/ additional supporting documents.

27 | P a g e
2.2.5.2. Review Court Order

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
FR-07.6.2-01 The system shall enable MoR lawyers to review the Court M
Order.
If the MoR lawyers decide to appeal the process of Tax
Litigation to Supreme Court or Tax Litigation to Cessation
Bench started.
If the MoR lawyers decide to not appeal then the system
shall enable MoR lawyers to prepare justification letter on
why not appealing and send to Team Leader for approval.

FR-07.6.2-02 The system shall enable Team Leader to review the M

justification letter.
If the team leader decide to appeal the process of Tax
Litigation to Supreme Court or Tax Litigation to Cessation
Bench started.

28 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
If the team leader decide to not appeal then the system
shall enable team leader to send recommendation letter
to Legal Director on why not appealing.

FR-07.6.2-03 The system shall enable Legal Director to review the case
on why not appealing to the next level court.
If Legal Director decides not to appeal then the process
stop.
If Legal Director decides to appeal to the next higher court
then the process Tax Litigation to Supreme Court or Tax
Litigation to Cessation Bench started.

2.2.6. Data Analytics on Tax Litigation Cases

29 | P a g e
 ID Requirement Description Priority Remark
Mandatory
(M) / Preferred
(P)
FR-07.4-01 The system shall enable Legal Department to identify and M
consolidate Data Analytic Requirements on Tax Appeal
Cases based on the request for data analytic reports from
State Minister and stakeholder.
FR-07.4-02 The system shall enable Legal Department to Use Self P Part of data
Service Data Visualization Tools for Adhoc Queries to the management/ data
Data Warehouses. warehousing /
business intelligence
project
FR-07.4-03 The system shall Create Report on Value of Tax Litigation M
Cases and Nature of Issues for Each Sectors/ Segments/
Tax Type
FR-07.4-04 The system shall Create Report on Average Age of Cases M
and Outcomes of Tax Litigation Cases for Each Sectors/
Segments/ Tax Type
FR-07.4-05 The system shall Create Report on Number of Tax M
Litigation Cases at beginning of period (mnth, quarter and
Year), Received during the period, Resolved during the
period and cases in hand at the end of period
FR-07.4-06 The system must have some basic core reports readily M
available for direct use by officers and officials. These
basic core reports on Tax Litigation Management shall be
defined during implementation/customization phase.
FR-07.4-07 For complex and cross cutting reports, the system shall M
enable the Legal Department to send the request to Data
Scientist stating the data requirement.
FR-07.4-08 The system shall have flexibility to enable MoR staff (Data M
Scientist) to create Customs Reports as Requested by
Legal Department.
FR-07.4-09 Based on the reports created, the Legal Department M
would Analyze Impact of Tax Litigation Cases on the
Policy/ Legal/ Operational and Create Recommendation.
FR-07.4-10 If the recommendations require state minister approval, M
the system shall provide an interface for State Minister to
review the request.
FR-07.4-11 Upon receiving approval from State Minister, the system M
shall send the recommendation letter to all related
Directorates and or taxpayers.
FR-07.4-12 The Legal Department would then monitor the follow up M
on Recommendation. The system shall enable the Legal
Department to record the monitoring results and send the
monitoring report to State Minister.

30 | P a g e
2.2.7. Directive Drafting

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
This is a manual process to be handled outside of ITAS.

31 | P a g e
2.2.8. Legal Advice and Training

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
This is a manual process to be handled outside of ITAS.

32 | P a g e
2.2.9. Legal Training

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
This is a manual process to be handled outside of ITAS.

33 | P a g e
2.2.10. Civil Cases Litigation

ID Requirement Description Priority Remark

Mandatory
(M) / Preferred
(P)
This is a manual process to be handled outside of ITAS.

3. Annexures

Annex 1. List of Acronyms

Abbreviations/
Definition
Acronym

BPT Business Process Transformation

BPMN Business Process Modeling and Notation

34 | P a g e
 Abbreviations/
Definition
Acronym

BRD Business Requirement Document

FRD Functional Requirement Document

ITAS Integrated Tax Administration System

MoR Ministry of Revenues

RNA Revised Notice of Assessment

TTO Tax Transformation Office

TADL Tax Appeal Decision Letter

Annex 2. Requirement Prioritization Convention

Value Rating Description
1 Mandatory This requirement is critical to the success of the project. The project will
not be possible without this requirement.
2 Preferred This requirement is somewhat important, as it provides some value but
the process can proceed without it.

Annex 3. Glossary of Terms

[If needed, identify and define any terms that may be unfamiliar to readers, including
terms that are unique to the organization, the technology to be employed, or the
standards in use.]

Annex 4. Related Reference Documents

[Provide a list of documents or web pages, including links, which are referenced in the
BRD/FRD.]

35 | P a g e