The Material Interest in Tax Law

The article addresses the issue of the lack of clarity regarding the content of the concept of material interest, as used in the Bulgarian Tax and Social Security Procedural Code in relation to the exercise of the right to appeal in cassation during the judicial phase of the review of the legality of audit acts of the tax administration. Material interest is determined by the amount of obligations established by the audit act, but not all acts result in the establishment of obligations. Therefore, a gap in the law is identified that cannot be filled through analogy or extensive interpretation.