Art. 54 Federal Law of October 13, 1965, on the Withholding Tax (WTA)
Art. 54 LIA
The decision issued on a claim by the cantonal withholding tax office may, within thirty days following its notification, be challenged through a written appeal to the cantonal appeals commission; the appeal must contain precise conclusions and state the facts that justify it. Art. 55 is reserved.
The appeals commission shall take the necessary investigative measures; Arts. 48 to 50 apply by analogy.
The Federal Tax Administration (FTA) must be given the opportunity to participate in the procedure and to submit conclusions.
The appeal procedure shall continue, notwithstanding the withdrawal of the appeal, if there are indications that the contested decision is not in accordance with the law, as well as if the federal administration or the cantonal tax administration has submitted conclusions and maintains them.
The appeals commission renders its decision on the appeal based on the results of its investigation, without being bound by the conclusions submitted.
The decision must be reasoned and indicate the avenue of appeal; it is communicated in writing to the persons directly concerned, as well as to the cantonal and federal tax administrations.