THE ESSENCE OF A PUBLIC LAW DISPUTE ON THE EXAMPLE OF CHALLENGING THE ACTIONS OF TAX AUTHORITIES IN THE JUDICIAL PRACTICE OF THE REPUBLIC OF KAZAKHSTAN
Keywords:
tax authority, public law dispute, administrative justice, prescription, challenge, tax audit, administrative actAbstract
The article examines the administrative and legal aspects of the regulation of public law disputes arising from tax relations in the Republic of Kazakhstan. The legal nature of the tax dispute as a type of conflict is revealed, and attention is focused on the ways to resolve them.
The article examines the procedural and institutional features of tax disputes, including the specifics of appealing administrative acts of tax authorities, the burden of proof, equality of the parties and the principles of administrative proceedings. The analysis of the regulatory framework, the provisions of administrative procedural legislation (APPC RK), judicial practice and doctrinal sources is also carried out. The issues of the normative judicial practice of the Supreme Court of the Republic of Kazakhstan in the subject of challenging the regulations on the appointment of tax audits deserve special legal attention. Based on the results of the study, it was concluded that there is a need for a detailed approach to the practice of tax administrative proceedings as an independent element of the administrative justice system.