Can the Tax Office reclaim benefits without clear substantiation?

After the Childcare Allowance scandal (2018-2020), substantiation requirements for clawbacks tightened. Clawback must be reasoned: which fact triggers which calculation, which statute applied, on what evidence. Awb art. 3:46 (duty to substantiate) + AWIR + new Tax Office benefits conduct rules — vague "your entitlement was revised" without figures is in principle untenable. What to do:

1. Demand full substantiation in writingwhich year, which income, which articles, which income difference triggered revision
2. Object within 6 weeks
3. For previously unfair clawbackscheck Toeslagen scandal safety-net (UHT, Recovery Office). Post-scandal success rates on objections are notably higher than pre-2020.