Regulation of relations with tax authorities has simplified the work of lawyers
In recent years, there have been positive changes in tax legislation. A number of clarifying provisions were adopted in the Tax Code of the Russian Federation, which very clearly regulated the procedure for interaction between the tax authority and the taxpayer during an audit, as well as the procedure for appealing decisions made.
In particular, two years ago, a procedure for appealing decisions of tax audits to a higher tax authority appeared.
This clearly defined mechanism for interaction with tax authorities has greatly simplified the life and work of lawyers. This became especially visible this year, while at the beginning of 2009 the positive aspects were offset by the overall difficult economic situation.
Officials are trying to delay the return of money to the taxpayer
Unfortunately, sometimes the appeal procedure is used by officials to delay, for example, the refund of overpaid tax to the taxpayer. After all, first, the same tax authority, whose employees carried out the on-site or desk tax audit, considers the taxpayer’s objections to the act. Then, if it is not possible to reach mutual understanding, the procedure of appealing the decision to a higher tax authority takes place. Only after this the taxpayer can go to court. All this takes quite a lot of time.
In our practice, we have had to deal with the fact that the tax authority abuses its right by not meeting the deadlines for appeal.  Sometimes inspectors directly say that “yes, we understand that in court you will “recoup” these amounts, but six months will pass before that. While the procedure for considering objections is completed, additional tax control measures and an appeal will be completed.”
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