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

Article 179. The form and content of a taxpayer’s (tax agent’s) complaint

1. A taxpayer (tax agent) shall file a complaint in writing.

2. The complaint must contain:

1) the name of the authorized body to which the complaint is submitted;

2) the last name, first name and patronymic (if it is indicated in an identity document) or full name of the person filing the complaint, his/her/its place of residence (location);

3) identification number;

4) the name of the tax authority that conducted a tax audit;

5) circumstances, on which a person submitting a complaint grounds his/her claims, and evidence supporting these circumstances;

6) the date of signing the complaint by the taxpayer (tax agent);

7) the list of attached documents.

3. The complaint may contain other information relevant to the resolution of the dispute.

4. The complaint is signed by a taxpayer (tax agent) or by a person who is his/her representative.

5. The following documents shall be attached to the complaint:

1) documents confirming circumstances, on which the taxpayer (tax agent) grounds his/her claims;

2) other documents relevant to the case.
Article 180. Refusal to consider a complaint

1. The authorized body refuses to consider a taxpayer’s (tax agent’s) complaint in case:

1) the taxpayer (tax agent) submits a complaint after the appeal period established by part one of paragraph 1 of Article 178 of this Code has expired;

2) of non-compliance of the taxpayer’s (tax agent’s) complaint with the requirements established by Article 179 of this Code;

3) a complaint is filed by a person who is not the taxpayer’s (tax agent’s) representative;

4) the taxpayer (tax agent) has filed a statement of claim on the issues set out in the complaint with court.

2. In the cases provided for in subparagraphs 1), 2) and 3) of paragraph 1 of this article, the authorized body shall notify the taxpayer (tax agent) in writing of its refusal to consider the complaint within ten business days from the registration of the complaint.

The authorized body shall notify the taxpayer (tax agent) of the refusal to consider the complaint in the case provided for in subparagraph 4) of paragraph 1 of this article, in writing, specifying a reason for such a refusal within ten business days from establishing the fact of the taxpayer’s (tax agent’s) appeal to the court.

3. In the cases provided for by subparagraphs 2) and 3) of paragraph 1 of this article, the authorized body’s refusal to consider the complaint does not deprive the taxpayer (tax agent) of the right to reappeal within the period established by part one of paragraph 1 of Article 178 of this Code, if he/she/it eliminates violations.