Pre-trial dispute resolution
The current legislation defines an alternative procedure for resolving disputes about challenging decisions, actions (inaction) of state revenue bodies. The applicant has the right to appeal: notification of the results of the audit to the authorized body or to the court; actions (inaction) of officials of state revenue bodies to a higher authority or to the court. Since July 1, 2017, an Appeals Commission has been established by the authorized body, the Ministry of Finance, to consider complaints about the notification of the audit results. The authorized body issues a reasoned decision, taking into account the decision of the Appeal Commission. From the analysis conducted by the authorized body, it follows that in the second half of 2017, it considered 70 complaints, of which 20 were satisfied (notifications were canceled). In the first half of this year, 134 complaints were considered, of which 53 or 40% were satisfied.
It should be noted that only one percent of the issues appealed by taxpayers relate to transfer pricing. During the study of the cases submitted for summary, it was found that in 17 of the 18 cases, taxpayers had previously appealed the notifications of the audit results out of court.
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