Journal of Tax Research

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Taxation proceedings system of our country with its special composition and structure is different from systems merely being administrative and two-step administrative-judicial systems. In this system, primitive and appeals dispute settlement boards like judiciary system investigate nature of disputes between taxpayer and taxation office and Supreme Tax Council and the Administrative Justice Court undertake investigation of the judgments issued from these boards parallel to each other. Appeals and objection to the judgments issued from primitive dispute settlement boards is one of the controversial subjects during these years. Legislation process, omission and revival of this step in taxation proceedings structure show that the legislator doesn’t consider nature, value and credit of appeals accurately. Although legislator considered it in the latest changes in this field and this step has been revived again in 2009, it should go miles to reach its suitable place. In the present paper, we study the place of substantial appeals in taxation proceedings appeal of Iran. It seems that based on current regulations, there are faults on composition and structure of tax dispute settlement boards which can be regarded as a barrier in the said boards to reach fair proceedings.

Keywords: Tax, Tax Dispute, Appeals, Dispute Settlement Board, Taxpayer, Tax Proceeding

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