Abstract

As a rule, a legal decision is given in order to decide incidental matters that appear sub judice before an administrative court. However, from the point of view of an accuser, who is a party in a dispute with the tax authority, the effectiveness a complaint decides upon further vindication of one’s rights. Complaints regarding decisions that impose multimillion tax obligation are matters of great importance, very often prejudging the economic sense of further functioning of an entity, which makes a complaint. The effectiveness of a complaint based on ignoring the claim, or quashing the proceedings, decides whether the dispute of a taxpayer with the authority will be recognized by an independent court, or if the tax decision becomes final.