Article 22 - Determination by the Authority

A. The Authority may reject to apply the provisions of the corresponding adjustments in any of the following cases:
1. Where the arrangement is considered artificial or abusive and to which Article 63(a) of the Law is, or the Authority determines it may be applicable.
2. In cases where a final decision has been made in relation to the subject matter of the Taxable Person’s claim by the competent judicial body and such decision is no longer appealable.

B. The statutory time limitations period established under Article 65 of the Law shall be applicable for the purposes of this Article.