Taxation is an important aspect of state sovereignty. For its existence and efficient operation, the state needs tax revenues collected from taxpayers by the Financial Administration of the Republic of Slovenia. The tax procedure, which is regulated by the Tax Procedure Act and supplemented by the General Administrative Procedure Act, is a special administrative procedure in which the rights and obligations of taxpayers are decided. In the event of violation of the rights in the tax procedure, taxpayers have the opportunity to file the only regular appeal - complaint. The right to appeal is regulated by the Constitution of the Republic of Slovenia in its Article 25. In addition to the appeal, taxpayers also have the possibility to apply irregular legal remedies. The General Administrative Procedure Act regulates five irregular legal remedies, while the Tax Procedure Act adds to these five additional irregular legal remedies specific cases of abrogation, annulment and amendment of the decision. After the use of these remedies, taxpayers have access to judicial protection over the decisions or actions of the authorities in the procedure. First, they can initiate an administrative dispute at the Administrative Court of the Republic of Slovenia, and later they can appeal to the Constitutional Court of the Republic of Slovenia and the European Court of Human Rights.
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