Abstract: A material dispute or commonly referred to as a material dispute occurs when there is a difference in the amount of tax owed or a difference in the amount of excess tax according to the tax authorities listed in the tax assessment, with the amount according to the calculation of the taxpayer. These differences of opinion may involve differences of opinion regarding the legal basis that should be used, different perceptions regarding a tax regulation provision, and a dispute or a certain transaction or it could be due to other reasons.