Lawyer Ilonka Kovacheva

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Appeals against tax audit acts

Appeals against tax audit acts, review of tax audit reports

Tax audit acts are declaratory acts which recognise existing rights such as the right of set-off and more. To be lawful one tax audit act, it must be issued in writing in compliance with all legal requirements. Very often, however, the requirements are not met and the tax audit act may be appealed.

Tax audit acts may be appealed against administratively and judicially. Lawyer Ilonka Kovacheva provides appealing against tax audit acts through administrative and judicial channels. Tax audit acts which are not issued in compliance with the law are subject to an appeal.

Appeals against audit reports administratively

The appeal of the tax audit acts administratively is regulated by the Tax and Social Security Procedure Code (TSSPC). The issued Tax audit act is subject to administrative appeal under Article 152-155 of TSSPC. Tax audit acts which are not issued in compliance with the law can be appealed against within 14 days from the date of issuance.

Appeals against tax audit acts judicially

The court is the second instance to appeal against the issued tax audit act. The appeal against the tax audit act allows the court to protect the legal interests of the taxpayer through judicial control. Court examines whether the conditions for the legality of the tax audit act referred to in Article 160 are kept. Only tax audit acts which are not issued in compliance with the law are subject to an appeal.

The decision of the Administrative Court can be appealed to the Court of Cassation under Administrative Procedure Code. The entire decision of the court of first instance or individual parts of it are subject to further appeal before the Court of Cassation. The decision of the Court of Cassation is final.

Lawyer Ilonka Kovacheva has a versatile legal practice and many years of experience in the field of tax law. Customers can rely on professional legal protection of their interests and finding the best legal solution for each situation.



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Tel.: +359(0)887 989 790
E-mail: ilonkakovacheva@abv.bg



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