Received a tax assessment notice (TAN) with an additional charge you consider unfair? It can be appealed — administratively or in court. We explain both routes, the deadlines and what to watch so you don’t lose your right to defence.

In brief

A TAN is appealed in two ways: administratively (a complaint to the higher-level tax authority — free, within 10 business days) or in court (the district administrative court — with payment of a court fee). While the appeal is pending, the amount is deemed unagreed and is not collected. The key thing is not to miss the deadlines: once they expire, the TAN becomes mandatory.

What a tax assessment notice is

A TAN is a decision by which the tax authority determines the taxpayer’s amount of monetary liability, penalty or interest (for example, following an inspection). From the moment a TAN is received, the taxpayer has a choice: agree and pay, or appeal. While the appeal procedure is pending, the liability is deemed unagreed — that is, it cannot be collected by force.

Administrative appeal

This is a complaint to a higher-level supervisory authority (the State Tax Service). Its advantages are that it is free and fast:

  • the complaint is filed within 10 business days of receiving the TAN;
  • the authority reviews it, as a rule, within 20 calendar days (the term may be extended);
  • while the complaint is under review, the amount remains unagreed.

If the outcome did not satisfy you — the court route remains.

Court appeal

The claim is filed with the district administrative court. This route is paid — a court fee is paid, the amount of which depends on the sum of the liability being appealed. You can go to court within the terms set by the Tax Code (taking into account the general limitation period of 1,095 days). A court appeal can be used both after the administrative one and straight away, without it.

ImportantThe most critical thing in tax disputes is the deadlines. If you miss the 10 business days for an administrative complaint or the term for going to court, you risk the TAN becoming agreed and payable, and it will no longer be possible to appeal it. So you must react to a received TAN immediately, not “when there is time”.

Frequently asked questions

How much time is there to appeal a TAN?

For an administrative complaint — 10 business days from receiving the decision. For a court appeal — the terms under the Tax Code, taking into account the 1,095-day limitation period.

Do you have to pay the additional charge while the appeal is pending?

No. While the liability is being appealed (administratively or in court), it is deemed unagreed and is not collected by force.

Which is better — a complaint to the tax authority or going straight to court?

The administrative appeal is free and fast, so it is often tried first. But for complex disputes, or when the independence of the decision matters, going straight to court is advisable. The optimal strategy is best chosen with a lawyer.

Received a tax assessment notice?

We will analyse the lawfulness of the TAN, choose an appeal strategy and prepare the complaint or claim — so you don’t pay more than you should.

Appealing a TAN →