Summarized results of the first stage of the draft regarding confirmation of the practical possibility of appealing the decisions of STS or SCSU, concluded by results of administrative appeal in the court.
The latest practice, including at the courts of appeal stage, indicates that such approach, proceeding from para. 56.10 of the Tax Code, is already applied by the courts in most cases.
This provides proceeding to the next stage of implementation of the ways of more effective tax disputes solution in case of unmotivated decision of STS by the results of claim consideration (para. 56.4, 56.9 of the Tax Code). The detailed analysis is provided in the article “Tax disputes: what you can do in a new way if tax authorities said “Just NO“”.
The above commentary presents the general statement for information purposes only and as such may not be practically used in specific cases without professional advice.