Legal Means of Ensuring Legality and Certainty in the Tax Process at the Stages of Appeal and Review of Tax Authorities Decisions

Purpose of the study. The modern tax process in the Russian Federation does not yet have the necessary degree of legal regulation that would fully ensure the legality and certainty of the actions and decisions of tax authorities at the stages of reviewing tax audit materials and appealing decisions made by tax authorities, of which, in the absence of reasonable grounds, decisions made in accordance with Article 101.4 of the RF Tax Code that are not subject to appeal are singled out into a separate category. Conclusions. The article proposes to establish in the tax law a specific deadline for the preparation of a tax authority decision on a taxpayer's case, oblige the tax authority to justify the reasons for missing this deadline, oblige the superior tax authority to formalize the fact of accepting the taxpayer's appeal for proceedings in a separate procedural document, introduce a new authority of the superior tax authority to terminate proceedings on the taxpayer's appeal, clarify the wording of the powers of the superior tax authority when considering the appeal on the merits, strengthen guarantees for the protection of the rights of persons brought to tax liability when appealing decisions made in accordance with 101.4 of the RF Tax Code, and introduce into the tax process a new institution for reviewing decisions of tax authorities that have entered into force under new circumstances.