Abstract
From a practical point of view, it is sometimes very difficult to ensure that the tax administrator actually makes decisions in the spirit of basic principles and principles, some of which have a constitutional dimension. In particular, it is about ensuring that the principle of legality is maintained ("there is no tax without the law").
In a number of specific cases, it is difficult to get rid of the impression that the tax administrator makes decisions based on his or her feelings, beliefs, political or philosophical orientation, and the law or the facts are merely a follow-up crutch but not in fact a guide for decision-making.The legality of decision-making, even in the field of taxation, is undoubtedly related to the degree of reviewability of such a decision. The article deals with how to ensure a higher degree of reviewability of tax authorities' decisions, in particular from the perspective of the legitimate interests of tax subjects.