Principles governing tax proceedings


Tax authorities are obligated to provide a taxpayer all necessary information and clarifications in relation to improper application of tax regulations directly tied to the taxpayer’s case. This is essential, as taxpayers frequently fail to pursue this route, adopting a passive position and not engaging in polemics with the tax authorities.

The taxpayer should also know that tax authorities are required to undertake all necessary actions to clarify the facts during tax proceedings and resolve the case at this stage if possible.

The tax authority should also explain to the taxpayer the reasoning behind its resolution of the case.

Under the law, the tax authorities must enable the taxpayer to participate at each stage of the proceedings, make demands, and comment on the evidence and other materials in the case prior to issuance of a decision.

The taxpayer has the right to inspect the case file at the premises of the tax authority conducting the proceedings, in the presence of an employee of the tax authority, and to take notes, copies and extracts. The taxpayer can also demand certified copies from the case file.

Prior to the issuance of the decision, the taxpayer can usually comment on the evidence and other materials and assert demands within 7 days of delivery of notification from the tax office.