It operates like a small court with quick decisions. Dispute Resolution Department. Those who are now applying to the TEN know in advance that their appeal must be very well “tied up”, otherwise it will be rejected. This can also be seen from the fact that the number of taxpayers’ applications for the cancellation of fines due to late submission of the declaration and, in general, in cases where they themselves know that they will not be corrected, as provided for by tax legislation, has significantly decreased. was bypassed.

At the same time, tax authorities’ inspection reports have recently improved, although not significantly, but sufficiently, as a result of which they do not leave an opportunity for tax evaders to demand the cancellation of an inspection on formal grounds. However, in any case – and as AADE statistics show – 3 out of 10 who applied to TEC in 2022 were justified.

According to AADE, 7862 applications were submitted last year, of which 7363 were closed. Of those considered, 1980 were justified (in whole or in part), and 4778 were rejected. Another 21 were brought to trial as taxpayers quit and 594 cases expired legally and were silently dismissed.

However, most of the taxpayers and businesses whose cases were rejected also applied to the administrative courts. It is noted that before cases get to the courts, you must first “pass” through the Dispute Resolution Department. In particular, 4132 taxpayers decided to go to court to defend their right. According to market leaders, TEN reports are so well structured that they serve as a guide for judges as well. In most cases, the judges agree with the decisions of the TEC, with the exception of those that were silently rejected and are usually the most difficult and strange.

Appeals must be very well documented or they will be rejected.

According to AADE, since 2013, when the TEN began its work (the formation of the TEN was the requirement of the Troika), 81,682 taxpayers and enterprises have filed appeals, disagreeing with the decisions of the tax authorities and the control and audit mechanism.

If the Dispute Resolution Directorate had not been set up, all these cases would have ended up in the administrative courts, most of which would not have been heard yet, given the volume of cases pending in the courts of first instance.

The creation of the TEN relieved the courts, and on the other hand, decisions are made in a very short time, which is in the interests of both the state and citizens.

According to the ADE, out of 81,682 cases referred to the TEC, 77,892 cases were heard in the period 2013-2022, of which 30,622 were referred to administrative courts. This development appears to have led to a reduction in the number of pending tax cases, which were over 100,000 before the Troika and are now around 20,000.