The Ministry of Finance should audit the treatment of Eurobond losses in each bank’s tax returns for each tax year, correct assessments and collect amounts established as due under the law. The Association of Banks in Lebanon’s letter to the Ministry, dated 19 September 2024 and registered under No. 10623 on 23 September 2024, raised the question of whether provisions for potential losses on these bonds could be deducted from taxable profits. This question was addressed in Opinion No. 11/2025 of the Legislation and Consultation Department, dated 14 January 2025, and subsequently in the Ministry of Finance’s clarification published on 3 November 2026. This requires verification of whether certain banks deducted provisions or valuation differences that the law does not permit, and whether this treatment reduced tax liabilities or generated tax losses available for carryforward. This review has direct human rights significance: collecting revenues legally due helps the State mobilize the maximum of its available resources to realize economic and social rights.^[1]

1. What the correspondence reveals

In its letter dated 19 September 2024, registered with the Ministry of Finance under No. 10623 on 23 September 2024, the Association of Banks in Lebanon requested acceptance of deductions for Eurobond portfolio revaluation losses and the corresponding provisions. It relied on an interpretation of Article 7(8) of the Income Tax Law under which the State’s debt obligations arising from the bonds fall within the provisions governing doubtful debts. The letter also raised separate issues, including the tax treatment of exchange rate differences and the revaluation of certain assets. The different nature of these items requires each to be examined under its applicable tax rule.^[2]

On 14 January 2025, the Legislation and Consultation Department concluded in Opinion No. 11/2025 that provisions for potential losses resulting from the State’s default on foreign currency Treasury bonds do not fall within the deductible reserve provided for in paragraph 8. Its reasoning distinguished a bank’s subscription to Treasury bonds from the lending operations it examined when interpreting the exception granted to banks. This conclusion is confined to the deductibility of provisions under the provision addressed in the opinion. Treatment upon a bond’s sale or settlement must be determined by the facts and legislation in force during the relevant period. Non-deductibility under paragraph 8 cannot be extended to every subsequent loss or transaction without identifying the applicable provision. The objection concerns deducting an accounting loss for tax purposes without a legal basis, rather than recognizing a loss required by the applicable accounting standards.^[3]

In a statement published on 3 November 2026, the Ministry of Finance explained that it had notified the Association of Banks of the opinion and requested amended returns, but that, as of the statement’s date, it had not begun examining the relevant tax files or issuing assessments. According to the Ministry’s example, a decline in the bonds’ value was deducted in determining the taxable result while the banks continued to hold the bonds, and the subsequent partial recovery in value was not added back. Identifying the returns, years and amounts concerned, and the effect of any correction, remains subject to examination of the records. The USD 600 million figure circulating in the media therefore requires verification before being relied upon to establish a tax debt or estimate budget revenues.^[4]

If confirmed by an audit of returns and records, the Ministry’s account reveals blatant selectivity in tax treatment: treating the decline in Eurobond values as a loss that reduces the tax base, then disregarding the partial recovery in value when prices rise. If these facts and the unlawfulness of the treatment are established, they warrant serious accountability for reducing tax liabilities at the public Treasury’s expense.

The Ministry of Finance must determine the scope and consequences of these practices for each bank and each tax year, and collect amounts established as due, together with legally prescribed penalties. If the audit reveals serious indications of acts that may constitute tax or financial offences, and the referral requirements are met, the facts and supporting documents should be referred to the Financial Public Prosecutor’s Office or the competent judicial authority for investigation and determination of responsibility, with respect for the presumption of innocence and defence rights. Communication between the tax administration and banks must not become a pretext for postponing audits or obstructing judicial referral when its requirements are met. The Treasury’s claims are public claims, and any manipulation calls for accountability and recovery of the amounts due.

The correspondence helps define the scope of verification. It sets out the Association’s position on deductibility, the Legislation and Consultation Department’s opinion on the provision invoked, and the administration’s position on amending returns. Proof, however, requires other documents, including portfolio transaction statements, accounting entries, returns and correspondence specific to each bank. Distinguishing these levels allows each document to be read according to its function and helps determine whether the dispute remained a matter of statutory interpretation or affected the tax calculation financially.

2. Unrealized losses and the tax base

A bond held by a bank may decline in value before a transaction establishes the investment’s outcome, such as a sale or final settlement. This decline has an economic effect that may require recognition in the financial statements. A revaluation loss differs from an expected credit loss. The former concerns measurement of the asset’s value, which may be affected by liquidity, interest rates and investor expectations. The latter estimates potential shortfalls in contractual cash flows based on credit risk. International Financial Reporting Standard 9 determines measurement and presentation according to the instrument’s classification, whether at amortized cost, fair value through profit or loss, or fair value through other comprehensive income.^[5]

Taxable profit is calculated by adjusting the accounting result in accordance with the law. A provision may be recognized in the financial statements and added back to profit when preparing the tax return. A difference between carrying amount and tax base may give rise to recognition of a deferred tax asset if the conditions of International Accounting Standard 12 are met. This entry represents a potential future tax effect, whereas deductibility of the provision from the current tax base is determined by law. The accounting entry, the adjustment in the return and the deferred tax effect should therefore be tracked separately.^[6]

In the Ministry’s illustrative example, the price fell from USD 1 to USD 0.06 per dollar of face value, then rose to USD 0.25: an initial decline of USD 0.94 followed by a recovery of USD 0.19, leaving the price USD 0.75 below its starting point. Face value does not necessarily equal acquisition cost or tax base. If the decline had previously been disallowed for tax purposes, this must be considered when examining the recovery to avoid an additional tax effect from reversing a charge previously disallowed, subject to any applicable provision requiring different treatment. If the decline had been deducted, the legality of that deduction and the treatment of the recovery must be verified. The relevant reference points are acquisition cost, tax base, entry and transaction dates, and original and amended returns.^[7]

Correcting the tax base may result in additional tax for the same year, a reduction in losses available for carryforward, or another outcome depending on the other adjustments. This makes reviewing subsequent years important. An unlawful deduction may continue to have an effect if a carried-forward loss is used to reduce later profits. Auditors must also examine whether the bank counted the same decline twice, once as a valuation difference and once as a provision, depending on the instrument’s classification and presentation.

The importance of distinguishing accounting measurement from the tax result becomes clear across successive years. A bond’s price may fall in one year and recover in the next while the bank continues to hold it. Upon sale or settlement, the final result should be reconciled with all previous adjustments, including amounts excluded from the tax base or accepted as deductions. This process makes it possible to calculate each transaction’s cumulative effect and identify the year in which it should be recognized, instead of aggregating separate entries that may concern the same bond and reflect different stages of its valuation.

3. Examining suspected tax evasion

A distinction must be drawn between the Association’s request for a particular interpretation and what each bank actually reported. An audit may reveal a disclosed interpretative disagreement, an error in an adjustment, or an impermissible deduction requiring correction of the assessment and administrative penalties where their conditions are met. Evidence of concealed sales, misleading information or false documents requires examination of responsibility under the applicable provisions and their constituent elements, including intent where required by law. Each bank has the right to submit documents and explanations and exercise its rights of objection and appeal.^[8]

Accountability requires evidence that can be tested. Reviewing a sample of revaluation entries alone does not show whether an amount actually reduced the tax base. Verification requires reconciling bond entries with financial statements, then with adjustment schedules and returns, and tracking amendments made following the Ministry’s correspondence. Reconciliation allows the administration to establish tax due, correct excessive assessments and identify cases requiring broader investigation.

Verification also helps distinguish the amount of the adjusted tax base from the amount collectible. The first adjustment measures the change in taxable profit or the loss balance, whereas tax is determined after applying the rules and rates in force. A further distinction must be made between amounts assessed, amounts contested and amounts actually paid. These stages provide a basis for explaining differences in reported figures and prevent provisions or initial assessments from being used as a final estimate of Treasury resources.

4. Public revenues and the enjoyment of economic and social rights

Article 2 of the International Covenant on Economic, Social and Cultural Rights requires the State to take steps, to the maximum of its available resources, towards progressively realizing rights and to guarantee their exercise without discrimination. In General Comment No. 24, the Committee on Economic, Social and Cultural Rights explains that excessive protection of bank secrecy and permissive corporate tax rules may limit a State’s ability to mobilize resources. Applying this obligation requires examining indicators of undercollection and enforcing rules consistently, enabling accountability for the administration’s management of public resources.^[9]

If unlawful deductions are shown to have reduced tax paid, the immediate effect falls on Treasury revenues. The impact on rights depends on budget choices and implementation. It may constrain funding for primary care and essential medicines, the operating costs of public schools and continuity of teaching, or expansion of effective social protection coverage. Monitoring service costs borne by households becomes particularly important, as the burden may increase for people on low incomes, persons with disabilities and those with caregiving responsibilities. Indicators of access to services, alongside expenditure figures, help demonstrate the impact of these choices on each group.^[10]

The World Bank estimated poverty at 44 per cent in 2022 in the five governorates covered by its survey. In this context, compensating for revenue shortfalls through consumption taxes or higher charges for essential services may increase the relative burden on low-income households. Assessing this impact requires knowing what different income groups pay and receive in services and transfers, and comparing available alternatives before adopting measures that may weaken the enjoyment of rights.^[11]

Addressing deposits and the financial gap remains a separate legal process. Tax established as due forms part of the Treasury’s claims, while banks’ obligations towards depositors are determined under their governing frameworks. If the timing of a substantial collection is found to affect a particular bank’s liquidity, that effect should be documented and coordination undertaken within lawful powers, taking account of small depositors’ interests and continuity of essential banking services. Any collection arrangement must have a statutory basis and be governed by reviewable criteria.

Two levels can be tracked when assessing human rights impacts. The first concerns the adequacy of appropriations for essential services and the extent of their execution. The second concerns outcomes for individuals, such as medicine availability at primary care centres, continuity of teaching in public schools and regular delivery of social protection benefits. Comparing outcomes across regions and income groups helps identify where a funding gap becomes an actual barrier to services, and where the problem lies in implementation or access conditions.

5. Audit collection and accountability

1. Identify audit assessment and collection deadlines and prevent Treasury claims from becoming time-barred

The Ministry of Finance should urgently prepare a schedule of the years and files concerned, distinguishing deadlines for recovering Treasury claims and issuing and notifying assessments from collection deadlines. Each deadline’s legal basis, starting date, relevant procedural acts and proof of their completion should be identified, with particular reference to Articles 43 and 56 of the Tax Procedures Law and their amendments. Initiating an audit does not, in itself, preserve the right to assess or collect tax.^[12]

Laws suspending or extending time limits, including Law No. 40/2025 where applicable, should be reviewed to identify the periods, taxes and procedures covered. Suspension of a filing or payment deadline should not be presumed automatically to extend to recovery of Treasury claims or collection. Ministry schedules may assist, but calculation of each deadline must be grounded in the legislation applicable to the file concerned.^[13]

Priority should be given to files approaching expiry or with the largest potential financial impact, unexplained differences between accounting and tax results, and substantial changes in provisions and carried-forward losses. Article 44 permits desk and field audits based on samples selected using risk analysis criteria. These are indicators for selecting files, rather than proof of a violation or evasion in themselves.^[14]

Priorities should be translated into a plan identifying the person responsible for each file and dates for requesting and examining documents, communicating preliminary findings, receiving comments, issuing and notifying assessments and following up collection, with deadline alerts and documented reasons for delays. General correspondence or requests for amended returns should not be presumed to suspend or interrupt limitation periods without a legal basis.

Collection must comply with warning, notification and enforced collection procedures, particularly Articles 63, 64 and 66. Article 64(4) provides that an enforced collection decision suspends the running of the limitation period for collecting the amounts it covers, without suspending penalties or interest. The decision, its notification and other conditions for its effectiveness must therefore be documented, distinguishing this effect from cases in which enforced collection proceedings are stayed.^[15]

Mobilizing resources to realize rights requires examining the causes of any unjustified administrative delay that resulted in the loss of taxes due, determining responsibility and taking corrective measures, while respecting time limits and taxpayer safeguards and applying equal criteria to all files.^[16]

2. Reconcile records by bank bond and year and document audit findings

The tax administration should reconcile records, returns and supporting documents for each bank, each Eurobond issue and each relevant year, reconstructing acquisition, valuation, sale or settlement and their accounting and tax effects, within its powers and applicable time limits.^[17]

The administration should request acquisition, sale, transfer and settlement records; bond quantities and prices; transaction dates and supporting documents; schedules of provisions, expected credit losses and their reversals; valuation bases; and price sources. Each portfolio’s accounting classification, changes to it and their reasons should be stated, because price movements alone do not determine their effect on profit or loss.^[18]

The data should be reconciled with schedules bridging accounting profit and taxable profit, separating amounts recognized in the accounts from tax additions or deductions and identifying the basis for each adjustment. Deductibility cannot be inferred from recognition of a loss, nor taxability from a price increase alone. Tax provisions must be applied to the facts, distinguishing carrying amount from tax base.^[19]

Auditors should verify that no loss or provision was deducted twice, that reversals or recoveries were treated as required by law, and that sales or settlements, their prices, dates and parties were genuine, rather than relying on aggregate entries unconnected to the bonds concerned.

Original and amended returns should be reviewed, with a record of changes, their reasons and effects, and carried-forward losses traced to the years in which they were used. Article 47(4) permits auditing losses carried forward from time-barred periods to accept, adjust or cancel their amount, without thereby reopening assessments for those periods. The effect of reducing carried-forward losses should be separated from any additional tax collectible.

Where permitted by law, data should be reconciled with information held by Banque du Liban, the Banking Control Commission and other competent bodies through documented, purpose-specific exchanges that respect confidentiality. Supervisory or accounting assessments do not replace tax assessments.

An audit file should link each finding to its supporting document, bond and year, explaining the calculation, the bank’s response and the reasons for accepting or rejecting the treatment, enabling review and objection and protecting the rights of both the Treasury and the taxpayer.

3. Issue reasoned assessments collect amounts due and refer suspected offences to the judiciary

After communicating preliminary findings and allowing banks to respond, the administration should issue individual, reasoned assessments identifying the facts, periods, legal provisions, reasons for accepting or rejecting the treatment, calculation of the tax base and tax, and effects of correcting provisions and carried-forward losses. Principal tax should be separated from penalties and interest, with the legal basis for each stated, so that the claim can be understood and reviewed.^[20]

Assessments should be duly notified, stating objection and appeal procedures, the competent bodies, applicable deadlines and the effect of any suspension where applicable. Objections should be examined impartially, substantive arguments addressed and proven errors corrected, in accordance with Articles 97–102 of the Tax Procedures Law.^[21]

Collection should proceed without unjustified delay or preferential treatment, distinguishing objections to an assessment from objections to an enforced collection decision. Article 66 governs stays of enforced collection proceedings for tax whose assessment is contested, subject to its conditions and rules on commencement of the stay. An objection to the enforced collection decision itself, however, does not stay enforcement unless the State Council so orders. The legal basis and conditions for any stay, instalment arrangement, settlement or reduction should be documented. Collection must not be suspended outside legally prescribed cases on the grounds of ongoing communication or awaiting a general settlement.^[22]

If an audit reveals serious indications of acts that may constitute tax or financial offences, and referral requirements are met, the facts and documents should be referred to the Financial Public Prosecutor’s Office or the competent judicial authority for investigation and determination of responsibility. Examination of suspected evasion should take account of the definition in Article 1 of the Tax Procedures Law, including deliberate conduct and use of unlawful means, while identifying the applicable penal provision and its elements in light of the facts, without presuming responsibility merely from a person’s official position.

A distinction should be drawn between an interpretative disagreement, a violation requiring correction of an assessment, and indications of criminal conduct requiring investigation. A correction alone does not establish an offence, and a tax dispute does not preclude examination of independent evidence of possible criminal conduct, with respect for the presumption of innocence, defence rights and file confidentiality.

Fair and effective collection supports resource mobilization for the realization of rights, alongside administrative accountability and prevention of arbitrariness and selectivity. The Special Rapporteur on extreme poverty and human rights has recommended strengthening tax authorities’ capacity, addressing abuses and ensuring accountability and remedies.^[23]

4. Publish reviewable aggregate results and link tax collection to accountability for public resources

Periodic aggregate reports should distinguish audited files, tax base adjustments, taxes assessed, disputed amounts and actual collections credited to the Treasury, explaining differences. A tax claim is not itself revenue collected.

Accountability for resource mobilization is grounded in Article 2 of the International Covenant on Economic, Social and Cultural Rights. Disclosure enables assessment of collection efforts and their relationship to funding health, education and social protection. This is an analytical connection: the Covenant does not prescribe a particular detailed tax reporting model.^[24]

This approach is supported by the Special Rapporteur on extreme poverty’s recommendations on participation, transparency, accountability and non-discrimination in revenue collection and access to fiscal data, and by the guiding principles on economic reform impact assessments concerning access to information, justification of choices and public debate and parliamentary oversight.^[25][26]

The International Monetary Fund’s Fiscal Transparency Code and the PEFA framework, particularly indicator PI-20 on revenue accounting and reconciliation, provide technical tools for designing disclosure and explaining differences between assessments, collections, arrears and transfers to the Treasury. These are guidance tools, distinct from human rights treaty obligations.^[27][28]

In practice, as a proposed application of these principles to the banking files, reports should include the following indicators, each presented separately:

• Audit coverage: the number of banks, files and tax years covered, distinguishing open and completed files and defining “file” to avoid inflated figures or double counting.
• Tax base adjustments: increases or reductions arising from audits, by tax year and type of corrected treatment, explaining that a tax base adjustment does not itself equal tax due or revenue collected.
• Corrections to carried-forward loss balances: reported balances, adjustments and balances accepted after audit, separating any estimate of their future tax impact from current collections.
• Taxes assessed: principal tax, penalties and interest, if any, separately, identifying amounts subsequently amended or cancelled.
• Disputed amounts: their value, stage of objection or appeal, whether collection is stayed under a legal basis or competent decision, and outcomes of concluded disputes, without assuming that an objection alone stays collection.
• Actual collections: cash receipts during the period, refunds and net collections, with offsets and non-cash settlements shown separately and their effects explained.
• Arrears: unpaid amounts due, classified by debt age and legal status, reasons for delay, collection action taken and reasons for considering any amounts uncollectible.
• Reconciliation with Treasury accounts: amounts collected, transferred and credited to Treasury accounts, differences between them, their causes and action taken to resolve them.

This monitoring is consistent with the areas covered by TADAT, including accurate reporting, dispute resolution, revenue management, accountability and transparency.^[29]

Quarterly publication with an annual overview is proposed, using reusable tables that include definitions, sources, calculation methodology and update dates. The currency of amounts and the exchange rate and date used for conversions should be stated. Results of audits of previous years should be separated from current collection, preventing double counting as amounts move between stages.

Publication should respect tax confidentiality through aggregate data that prevent disclosure of protected information or re-identification of those concerned, while making details available to oversight bodies within their powers. Material differences, delays and corrective actions should be explained, without using confidentiality to withhold the administration’s overall performance results.

This enables Parliament, the Commission and the public to hold the administration accountable for resource mobilization and fair enforcement, alongside independent monitoring of expenditure’s effects on services and rights.

5. Show the effect of actual resources on the budget and services and strengthen monitoring of human rights obligations

The Government should explain the relationship between collected revenues and appropriations and programmes that strengthen health, education and social protection, drawing on the methodology of the 2014–2019 National Human Rights Action Plan for setting priorities, costing, assigning responsibility, oversight and evaluation. This plan should not be presented as a current implementation plan; the status of any subsequent plan or updated monitoring mechanism should be verified.^[30]

To translate these directions into monitorable action, it is proposed that the Government attach to the draft budget a statement identifying social spending objectives, the cost of proposed measures, responsible bodies and implementation dates. This should explain how appropriations contribute to health care and medicines, continuity of public education and improvements in its environment and equipment, and wider access to social protection benefits. The statement should also explain the basis for distributing resources across regions according to needs and existing gaps, and how priority is given to individuals and households most exposed to deprivation.

Periodic reports should compare appropriations, expenditure and achieved results, using indicators such as the share of the population covered by health and social protection, treatment costs borne by households, regularity of medicine and assistance provision, and school enrolment and dropout rates. Where possible and with respect for privacy, data should be disaggregated by region, sex, age, disability and economic status to identify who benefited from spending and who remained excluded, and determine reasons for delayed or weak implementation and measures needed to address them.

Baseline values and annual targets should be set for indicators, administrations assigned responsibility for supplying data, and results made available to Parliament, the Commission and the public. Affected groups and civil society should participate in assessing results and correcting disparities and shortcomings.

To follow up on this opinion, it is proposed that the Commission request information from the Ministry of Finance on audit procedures, years covered, measures taken to preserve Treasury claims and available aggregate results, including the date, reference number and content of the request for amended returns notified to the Association of Banks. The Commission should follow up on the response, publish a human rights assessment that respects tax confidentiality and request further data where needed.

Accountability begins with identifying which returns were actually corrected, which years require audit and whether taxes remain payable. Reasoned assessments, collection data and budget execution accounts enable the process to be traced from establishing the Treasury’s claim to assessing how resource mobilization affects access to essential services.

[1] United Nations, International Covenant on Economic, Social and Cultural Rights, 16 December 1966, Article 2(1) and (2). https://2covenants.ohchr.org/About-ICESCR.html

[2] Association of Banks in Lebanon, “Letter to Minister of Finance Dr. Youssef Khalil concerning the meeting with the Association’s delegation on 18 September 2024”, 19 September 2024, registered with the Ministry of Finance under No. 10623 on 23 September 2024, pp. 1–2 of the Association’s letter in the attached file, particularly items 1 and 2. https://nhrclb.org/wp-content/uploads/2026/11/7045.pdf

[3] Lebanese Ministry of Justice, Legislation and Consultation Department, “Opinion No. 11/2025 on the application of Article 7(8) of the Income Tax Law to provisions for foreign currency Treasury bonds”, 14 January 2025, pp. 4–7, particularly the conclusion on p. 7. See also Legislative Decree No. 144 of 12 June 1959, as amended, Article 7(8). https://nhrclb.org/wp-content/uploads/2026/11/10623.pdf https://lebanonlaws.com/laws/income-tax/articles/7

[4] Lebanese Ministry of Finance, clarification on the tax treatment of Eurobond losses and the amount circulating in the media, 3 November 2026. https://www.mtv.com.lb/news/1754729

[5] International Accounting Standards Board, IFRS 9 Financial Instruments, paragraphs 4.1.1–4.1.4 on classification and measurement and paragraphs 5.5.1 et seq. on impairment and expected credit losses. Standard webpage and full text, respectively: https://www.ifrs.org/issued-standards/list-of-standards/ifrs-9-financial-instruments/ https://www.ifrs.org/content/dam/ifrs/publications/pdf-standards/english/2022/issued/part-a/ifrs-9-financial-instruments.pdf?bypass=on

[6] International Accounting Standards Board, IAS 12 Income Taxes, paragraph 24, and the January 2016 amendments on deferred tax assets relating to unrealized losses on debt instruments measured at fair value. See also the Lebanese Income Tax Law, Article 7. https://www.ifrs.org/issued-standards/list-of-standards/ias-12-income-taxes/ https://lebanonlaws.com/laws/income-tax/articles/7

[7] The numerical example is drawn from the Lebanese Ministry of Finance’s clarification of 3 November 2026. For the distinction between carrying amount and tax base, see International Accounting Standards Board, IAS 12 Income Taxes. https://www.mtv.com.lb/news/1754729 https://www.ifrs.org/issued-standards/list-of-standards/ias-12-income-taxes/

[8] Lebanese Republic, Tax Procedures Law, Law No. 44 of 11 November 2008, as amended, particularly Article 44 on desk and field audits and provisions on assessment, objection and appeal. Links below: Ministry of Finance legislation; Article 44; and the Ministry’s published text containing the definition of tax evasion in Article 1. This definition does not dispense with identifying the applicable penal provision and its elements in each case. https://finance.gov.lb/ar-lb/Taxation/LRT/TP https://lebanonlaws.com/laws/tax-procedure/articles/44 https://www.finance.gov.lb/en-us/Taxation/LRT/TP/Documents/قانون%20الاجراءات%20الضريبية.pdf

[9] United Nations, International Covenant on Economic, Social and Cultural Rights, Article 2. See also Committee on Economic, Social and Cultural Rights, General Comment No. 24 on State obligations under the International Covenant on Economic, Social and Cultural Rights in the context of business activities, E/C.12/GC/24, 2017, paragraphs 37 and 38. https://2covenants.ohchr.org/About-ICESCR.html https://digitallibrary.un.org/nanna/record/1304491/files/E_C-12_GC_24-EN.pdf

[10] United Nations, International Covenant on Economic, Social and Cultural Rights, Articles 9 on social security, 11 on an adequate standard of living, 12 on health and 13 on education, read together with Article 2. https://2covenants.ohchr.org/About-ICESCR.html

[11] World Bank, Poverty and Equity Brief Lebanon, October 2025, p. 1. The estimate in the brief is confined to the five governorates covered by the survey. https://documents1.worldbank.org/curated/en/099650404212537932/pdf/IDU-6ba48130-f0ba-4b84-afda-eb5d23aa20d1.pdf

[12] Lebanese Republic, Tax Procedures Law No. 44/2008, as amended, particularly Article 43 on limitation periods for recovery of Treasury claims and Article 56 on collection limitation periods; the version in force in each period and legislation suspending time limits must be consulted. Ministry of Finance published text: https://www.finance.gov.lb/en-us/Taxation/LRT/TP/Documents/قانون%20الاجراءات%20الضريبية.pdf

[13] Lebanese Ministry of Finance, “Law No. 40/2025 (Law Suspending Time Limits)” webpage, including references and tables on expiry dates; the applicable text and its effect must be verified for each period and procedure. https://www.finance.gov.lb/ar-lb/Taxation/LRT/Pages/Law40.aspx

[14] Lebanese Republic, Tax Procedures Law No. 44/2008, as amended, Article 44, particularly paragraph 1 on selecting audit samples using risk analysis criteria. https://lebanonlaws.com/laws/tax-procedure/articles/44

[15] Lebanese Republic, Tax Procedures Law No. 44/2008, as amended, Article 64, particularly paragraphs 1, 3 and 4 on issuing, notifying and bringing into effect enforced collection decisions and their effect on limitation periods, and Articles 63 and 66. Ministry of Finance text: https://www.finance.gov.lb/en-us/Taxation/LRT/TP/Documents/قانون%20الاجراءات%20الضريبية.pdf

[16] United Nations, International Covenant on Economic, Social and Cultural Rights, Article 2(1) and (2). See also Special Rapporteur on extreme poverty and human rights, report on fiscal policy, taxation and human rights, A/HRC/26/28, 22 May 2014, paragraph 79, particularly the introductory text and subparagraph (b) on strengthening tax authorities. https://2covenants.ohchr.org/About-ICESCR.html https://documents.un.org/doc/undoc/gen/g14/033/74/pdf/g1403374.pdf

[17] Lebanese Republic, Tax Procedures Law, Law No. 44 of 11 November 2008, as amended, particularly Article 44 on desk and field audits, and related implementing provisions. Ministry of Finance legislation and text of Article 44, respectively: https://finance.gov.lb/ar-lb/Taxation/LRT/TP https://lebanonlaws.com/laws/tax-procedure/articles/44

[18] International Accounting Standards Board, IFRS 9 Financial Instruments, paragraphs 4.1.1–4.1.4 on classification and relevant provisions on subsequent measurement, impairment and expected credit losses. https://www.ifrs.org/issued-standards/list-of-standards/ifrs-9-financial-instruments/

[19] International Accounting Standards Board, IAS 12 Income Taxes, on the distinction between carrying amount and tax base and temporary differences. See also Lebanese Income Tax Law, Article 7. For auditing losses carried forward from time-barred periods, see Tax Procedures Law, Article 47(4), in the Ministry of Finance’s published text. https://www.ifrs.org/issued-standards/list-of-standards/ias-12-income-taxes/ https://lebanonlaws.com/laws/income-tax/articles/7 https://www.finance.gov.lb/en-us/Taxation/LRT/TP/Documents/قانون%20الاجراءات%20الضريبية.pdf

[20] Lebanese Republic, Tax Procedures Law, Law No. 44 of 11 November 2008, as amended, and implementing provisions on auditing and assessment, including provisions on comments on preliminary audit findings, published by the Ministry of Finance. https://www.finance.gov.lb/ar-lb/Taxation/LRT/TP

[21] Lebanese Ministry of Finance, “Objection and Appeal”, referring to Articles 97–102 of the Tax Procedures Law and their application. See also the legislation index, including the reference to Law No. 40/2025 on suspension of time limits; its scope must be verified against the legislation in force and the period concerned. https://www.finance.gov.lb/ar-lb/Taxation/Intercept-Appeal https://finance.gov.lb/ar-lb/Taxation/LRT/TP/Pages/default.aspx

[22] Lebanese Republic, Tax Procedures Law, Article 66, particularly paragraphs 1(c), 2 and 4, distinguishing objections to assessments from objections to enforced collection decisions. Ministry of Finance published text; see also Ministry of Finance, stages of objections, common provisions section. https://www.finance.gov.lb/en-us/Taxation/LRT/TP/Documents/قانون%20الاجراءات%20الضريبية.pdf https://www.finance.gov.lb/ar-lb/Taxation/Intercept-Appeal/SO/

[23] United Nations, International Covenant on Economic, Social and Cultural Rights, Article 2(1). See also Special Rapporteur on extreme poverty and human rights, report on fiscal policy, taxation and human rights, A/HRC/26/28, 22 May 2014, paragraph 79, particularly subparagraphs (b), (i) and (k). https://2covenants.ohchr.org/About-ICESCR.html https://documents.un.org/doc/undoc/gen/g14/033/74/pdf/g1403374.pdf

[24] United Nations, International Covenant on Economic, Social and Cultural Rights, 16 December 1966, Article 2(1) and (2), and Articles 9, 11, 12 and 13. https://2covenants.ohchr.org/About-ICESCR.html

[25] Special Rapporteur on extreme poverty and human rights, Magdalena Sepúlveda Carmona, report on fiscal policy, taxation and human rights, A/HRC/26/28, 22 May 2014, particularly paragraph 79, introductory text and subparagraphs (a) and (g). https://documents.un.org/doc/undoc/gen/g14/033/74/pdf/g1403374.pdf

[26] Independent Expert on the effects of foreign debt and other related international financial obligations of States on the full enjoyment of all human rights, Guiding principles on human rights impact assessments of economic reforms, A/HRC/40/57, 19 December 2018, principles 19 and 20, particularly paragraphs 19.3, 19.5, 20.1 and 20.2. https://digitallibrary.un.org/record/1663025/files/A_HRC_40_57-EN.pdf

[27] International Monetary Fund, “How Does the IMF Encourage Greater Fiscal Transparency?”, 2 February 2023, updated April 2025, particularly the discussion of fiscal reporting among the pillars of the Fiscal Transparency Code. https://www.imf.org/en/about/factsheets/sheets/2023/how-does-the-imf-encourage-greater-fiscal-transparency

[28] Public Expenditure and Financial Accountability programme, PEFA Framework 2016, indicator PI-20 on accounting for revenue, particularly dimension 20.3 on revenue accounts reconciliation. See also PEFA Assessment Fieldguide, second edition, guidance on dimension 20.3. https://www.pefa.org/node/4601 https://www.pefa.org/node/4866

[29] World Bank, Global Tax Program, “Knowledge Center”, concerning the Tax Administration Diagnostic Assessment Tool (TADAT). See also TADAT’s official website, performance outcome areas. https://www.worldbank.org/en/programs/the-global-tax-program/knowledge-center https://www.tadat.org

[30] National Human Rights Action Plan in Lebanon 2014–2019, published on the National Human Rights Commission’s website. https://nhrclb.org/wp-content/uploads/2024/10/LBN_NHRAP_2014_2019_AR.pdf

هذه المقالة متاحة أيضًا بـ: