Thoughts on the connection between tax administration procedures and the administrative procedure

This paper examines the theoretical aspects of exploring the relationship between tax administration and general administrative procedures. Some regimes include the tax administration procedure within the scope of the general administrative procedure, either making the latter primary or secondary to the former. Other regimes explicitly separate the two and treat the tax administration procedure as an excluded procedure. The paper presents a theoretical perspective on two regimes that embody these two approaches. One is the German system, where separate tax administration regulations were established early on and have remained in place ever since. The other is the American system, where uniformity is theoretically upheld, but a constantly evolving system of relationships has developed in practice.While the Anglo-Saxon system is largely distinct, the arguments put forward are certainly worth considering. Drawing on evidence from these systems, the study then formulates some general points which may contribute to a theoretical solution to the question.