Abstract

Th e article is devoted to a problem which appeared in progress of evolution of a premise to renew tax procedures. Th e basis to challenge a fi nal decision is revealing new circumstances or evidence. Evolution of law regulations caused the fact that constructing a regulation creates an excessive facility to renew a procedure on such basis. Faulty instance regulation is accompanied by a possibility to use new evidence in progress of judicial review. Total evaluation of cumulating of these regulations leads to a conclusion of an immediate change, especially in the light of current works on reform on general tax law.