On taxes and other obligatory payments to the budget (Tax Code)

Article 181. Procedure for considering a complaint submitted to the authorized body

1. A reasoned decision on a taxpayer’s (tax agent’s) complaint shall be made within thirty business days from the complaint’s registration, and on complaints of taxpayers subject to tax monitoring - within forty-five business days from the complaint’s registration, except for cases of extension and suspension of the terms of consideration of the complaint in accordance with Article 183 of this Code.

2. The authorized body, when considering a taxpayer’s (tax agent’s) complaint, has the right to schedule a thematic audit, as well as a repeat thematic audit in accordance with the procedure set forth in Article 186 of this Code.

3. Consideration of a complaint is limited to the issues complained of by the taxpayer (tax agent).

4. If, for consideration of his/her/its complaint, a taxpayer (tax agent) submits documents not produced during a tax audit, the authorized body is entitled to verify such documents during thematic and (or) repeat thematic audits fixed in accordance with the procedure set forth in Article 186 of this Code.

5. When considering a taxpayer’s (tax agent’s) complaint, the authorized body, if necessary, has the right:

1) to send written requests to the taxpayer (tax agent) and (or) to the tax authorities that conducted the tax audit and considered the taxpayer’s (tax agent’s) objections to a preliminary tax audit act, for additional information or explanations on the issues specified in the complaint;

2) to send inquiries to state bodies, relevant bodies of foreign states and other organizations about issues within the competence of such bodies and organizations;

3) to meet with the taxpayer (tax agent) for discussing issues specified in the complaint;

4) to ask tax officials that participated in the tax audit and considered the taxpayer’s (tax agent’s) objections to the preliminary tax audit act, for additional information and (or) explanations on arising issues.

6. It is prohibited to interfere with activities of the authorized body exercising its powers to consider the complaint and to exert influence on the persons involved in the complaint’s consideration.