Reasoned Opinion of a Tax Authority: The Legal Nature and Opportunities for Appeal

This article examines the legal nature of the motivated opinion of the tax authority as the final document adopted in the tax monitoring procedure, taking into account the tasks it solves, initially formulated by the legislator when introducing a new form of tax control. The author substantiates the possibility of judicial appeal of the motivated opinion of the tax authority in the context of its legal nature as a non-normative (individual) act. Taking into account the existing law enforcement practice, the author has attempted to assess ways to protect the rights of taxpayers in case of disagreement with the content of a reasoned opinion and the prospects for the development of legal regulation and law enforcement in this area.