Abstract

The article attempts to evaluate current regulations and practical consequences of their application regarding compliance with the constitutional principle of proportionality and trust of a citizen to activities of authorities, including tax authorities. The author describes general rules of functioning of institution of blocking bank accounts regarding a negative result within the ICT accounting system (STIR) in order to shed light on practices that raise doubts in the context of the constitutional principle of proportionality and trust to tax authorities. According to statistics, while making the decision in regard to blocking accounts for 72 hours the chief of the National Revenue Administration extended it for additional 3 months every time. Such a state of affairs is extremely dangerous, because according to the chief of the National Revenue Administration proceedings to take evidence conducted in those cases may be limited to the analysis of risk generated by IT tools based on the algorithm unverified by a taxpayer. So far, judicature of administrative courts doses not help the taxpayers. The judicature confirms that the actions of revenue administration comply with the law. The issue has not been evaluated by the National Administrative Court, of which judicature may be a chance to change those unconstitutional practices.