Kalyan, K. V. Legal Regulation of the Length of Periods for Court Appeal of Tax Authorities Acts

Abstract: The author of the article analyzes the conflict-of-laws problem of regulating the length of periods for court appeal of tax authorities acts pursuant to Article 56, Clauses 56.18 and 56.1 that regulate the solution of the aforesaid problem in different ways. In the author’s opinion, it is impossible to apply generally accepted methods of legal interpretation to this conflict of laws. The author also clarifies the causes of this conflict. He establishes that in this case it is better to apply the Tax Code provisions that interpret the present conflict of laws in favor of a taxpayer and by doing so, eliminate any arguments that may arise in the course of performance of obligations by the taxpayer. In his study the author of the article has used the following general scientific methods: systems analysis method, dialectical method, analogy and generalization methods. The author has also applied special methods such as the formal logical, systems functional and logical legal methods. The present article is one of the first to pay attention to the conflict-of-laws problem of regulating the length of periods for court appeal of tax authorities acts in the Ukraine. Based on the results of his study, the author concludes that it is impossible to apply generally accepted methods of legal interpretation to this conflict of laws. The author clarifies the causes of this conflict and analyzes tax law provisions that set forth the procedure for calculating limitation periods applicable to the aforesaid conflict of laws.

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