Administrative Order of Protection of Rights and Legitimate Interests of the Taxpayers
The administrative procedure for the protection of violated rights of taxpayers means the possibility of appealing the acts of tax authorities, actions or inaction of their officials to a higher tax authority (a higher-ranking official) or to a court. In the tax law, the administrative appeal procedure does not have the nature of a mandatory pre-trial procedure, so submitting a complaint to a higher tax authority (the higher official) does not exclude the right to the same or the subsequent filing of a similar complaint with a court. Within the framework of this article, some topical issues have been considered to establish the procedure for considering the complaint of taxpayers, the timing of consideration of such complaints, the effectiveness of the tax authorities, to which such complaints will be filed. An important part of the article is devoted to the analysis of theoretical and practical aspects of the administrative procedure for protecting the rights and legitimate interests of taxpayers. In particular, the problems of improving the structure of the work of tax authorities, their interaction with citizens filing complaints on certain acts of tax authorities or their officials are considered. From the authors’ point of view, such problems are of paramount importance for the effective and qualitative implementation of this procedure for protecting the rights and legal interests of taxpayers.