The influence of the higher court practice upon the taxpayers’ procedural guarantees (through the separate procedural stage of proceeding the results of a tax audit)

Zimulkin M. I.

The article examines the legal consequences of the influence of the positions of the higher courts on the level of procedural guarantees of the taxpayers. The author reveals the importance of procedural provisions of the tax legislation, points to the model formulated by the legislator and presents the results of its implementation in law enforcement practice. As an example, the author points to a change in the law enforcement approach in terms of individual stages of registration of the results of a tax audit. Based on the results of the study, the author concludes that the previously existing law enforcement approach has been changed, that the obligatory procedural tax and legal norms have been reduced and that the guarantees of taxpayers' rights laid down by the legislator have been reduced.

Keywords:tax, tax legal proceeding, tax procedures, tax control, judicial practice, tax audit act