Expanding Powers of Higher Tax Authorities in Tax Process at the Stage of Resolving the Issue of Acceptance of Complaint for Consideration

Purpose of the study. In the tax process there are no procedural principles of equality of arms and competition, since the tax authority, being an authority, prevails over the taxpayer at all stages. In this regard, in the tax process it is necessary to ensure an increased degree of protection of taxpayers’ rights from the free internal conviction of higher tax authorities at the stages of filing and considering taxpayer complaints. Conclusions. A classification of non-normative legal acts issued by tax authorities and subject to independent appeal is proposed, with the need to exclude from the tax law such an uncertain concept as «acts of tax authorities of a non-normative nature». At the same time, through an amendment to the tax law, it is proposed to oblige the higher tax authority to issue a separate procedural document in the form of a ruling on accepting the complaint for consideration, as well as to provide the named tax authorities with a new authority when deciding on the issue of accepting the complaint for consideration to abandon the complaint without progress.