The legislative amendments made to the Tax Code of the Russian Federation have improved the procedure for pre-trial appeal of tax disputes. Pre-trial appeal of a tax dispute provides for the possibility of filing a complaint with a higher tax authority.
Therefore, what has been changed?
- tax authority may suspend consideration of the complaint at the request of a person who filed the complaint for no more than 6 months;
- consideration of the complaint may be suspended by a decision of a higher tax authority until the court resolves another case in the course of legal proceedings;
- the term of consideration of the complaint may be interrupted or recalculated, for example, when the applicant provides additional documents.
Moreover, amendments in tax legislation provide for new grounds for leaving the complaint without consideration, namely:
- tax dispute on the same subject and on identical grounds has been previously resolved by court;
- company that filed the complaint was subsequently excluded from the Unified State Register of Legal Entities or liquidated.