(1) The taxpayer included in the Alternative Dispute Resolution process shall have the right to participate in mediation with the representative of the Commissioner himself or through his authorized representative.
(2) In alternative dispute resolution mediation, the taxpayer shall be limited to presenting legal and factual documents and arguments along with the related disputed issues.
(3) If an agreement can be reached, the taxpayer shall pay any tax imposed on the basis of the agreement within the agreed period.