Challenging tax authority actions

A tax authority decision, action, or failure to act may be challenged before the higher tax authority or in the administrative court. A complaint suspends enforcement of the disputed decision. An administrative complaint against a tax-audit or field-inspection decision must be filed within one month; the general court-filing period is six months.

In brief:

• A person may challenge a non-regulatory instrument, decision, action, or failure to act that the person believes infringes their rights.
• A complaint against an audit or field-inspection decision is filed through the authority that made it within one month (Article 232, Tax Code).
• The complaint is written or electronic and must identify the applicant, disputed instrument or conduct, authority, grounds, and requested relief.
• A higher-authority complaint is free; businesses and individuals are exempt from duty when filing in the administrative court.
• Registration of the complaint stops collection of the disputed additional assessments and sanctions until the dispute is decided.

Updated: 05 September 2026

What can be challenged

Any person who considers their rights infringed may bring a challenge. The Tax Code covers non-regulatory instruments (Article 230, Tax Code), decisions, actions, and failures to act by tax officials. A non-regulatory instrument is a document addressed to one or more persons that directs them to perform legally significant acts.

In practice, a complaint may concern an additional tax and financial-sanction assessment, a refusal to perform a legally required act, an unlawful collection, a demand for documents, or a procedural breach during the review of inspection materials. A tax authority’s regulatory instrument may also be challenged, but under the court procedure for departmental regulatory instruments.

If the higher authority or a court cancels a decision following a field inspection or tax audit, amounts collected or paid voluntarily must be refunded or credited with interest (Article 230, Tax Code). Interest is calculated using the Central Bank refinancing rate in effect during the collection or payment period.

This article does not cover inspection types, limits on control measures, or suspension of bank transactions as an independent measure. The article on tax inspections explains which inspections the tax authority conducts and how their results are documented. Use it when the dispute begins before a decision is made.

Where to file a complaint

The applicant may choose administrative review or court proceedings. The Tax Code permits a complaint to be sent to the higher authority or court (Article 231, Tax Code); the current rule does not make a prior complaint to the higher tax authority mandatory for this category of dispute.

Within the administrative chain, a district or city inspectorate decision is challenged before the higher tax authority. A non-regulatory instrument adopted by a district inspectorate or territorial department after reviewing a complaint may then be challenged before the Tax Committee. A non-regulatory instrument of the Tax Committee itself, and an action or failure to act by one of its officials, is challenged in court.

The chosen route affects the remaining procedure. If the taxpayer has already gone to court on the same issue, the higher tax authority will leave the administrative complaint unreviewed. Identical relief should therefore not be pursued simultaneously through both routes, although timely notice to the tax authority of a court complaint is required to suspend enforcement.

Which filing periods apply

The period depends on the subject and chosen route. A special one-month period applies to decisions following tax audits or field inspections; the general period applies to other administrative instruments and actions unless another period is set by a special rule.

An audit or field-inspection decision generally takes effect one month after service. It must be served within two days after adoption, and a registered letter is deemed served on the fifth day after dispatch. These service-date rules (Article 160, Tax Code) help establish the beginning of the period, but if the document was actually reviewed earlier, the earliest verifiable date should be used.

For a court application, it is important not to wait for the higher authority’s answer beyond the six-month period. The Supreme Court Plenum explained that administrative review does not shift the start of the court period to the date of the higher authority’s answer; it continues to run from the lower authority’s decision. The exception concerns a complaint left without review (paragraph 20, Plenum Decision No. 4).

A missed period may be restored for a valid reason. For an administrative complaint, the restoration request is included in the complaint and evidence of the reason is attached. The court restores its own filing period; late filing alone does not prevent acceptance of the application, but refusal to restore the period leads to dismissal of the requested relief.

Deadline example

A company reads a decision in its taxpayer account on 8 September. The one-month administrative period runs from the verified date on which the company learned of the infringement and ends on the corresponding day of the following month. If the company first files an administrative complaint, it must simultaneously track the six-month court period from the original date; the higher authority’s answer does not start a new six-month period.

What to do before filing

First distinguish objections to an inspection report from a complaint against the resulting decision. A taxpayer’s signature acknowledging receipt of a tax-audit report does not signify agreement. Written objections are due within ten days (Article 156, Tax Code) after receipt of the report, and documents rebutting the inspectors’ findings may be attached.

Audit or field-inspection materials are reviewed after ten but no later than fifteen days following preparation of the report. The tax authority must notify the taxpayer at least two working days (Article 158, Tax Code) before the review. The taxpayer may participate personally or through a representative, give explanations, and submit documents, including documents received after the applicable period.

Legal entities and individual entrepreneurs exchange documents with the tax authority through the taxpayer account. An electronic document is deemed received when read, but no later than three days (Article 19, Tax Code) after dispatch. A document sent by the taxpayer through the account is deemed received by the authority on the dispatch date. Before filing, retain the decision, notice, reading date, dispatch receipt, attachments, and delivery-status screen.

How to prepare and file the complaint

A complaint against a field-inspection or audit decision is addressed to the higher tax authority but filed through the authority that made the decision. That authority must forward it within three days (Article 232, Tax Code), together with the complete file.

The complaint and attachments may be filed in writing or electronically. The applicant or representative signs it. The Tax Code requires five groups of information (Article 233, Tax Code):

1. the individual’s full name and residence, or the legal entity’s name and address;
2. the challenged non-regulatory instrument, decision, action, or failure to act;
3. the tax authority whose instrument or conduct is challenged;
4. the grounds on which the applicant considers their rights infringed; and
5. the relief requested by the applicant.

A telephone number, email address, and other contact details may be included. A representative attaches proof of authority. Evidence is not described as a mandatory attachment, but it connects the facts to the grounds: the inspection report and decision, calculations, primary documents, correspondence, taxpayer-account receipts, objections to the report, and the record of the materials review.

The requested relief should stay within the reviewing authority’s powers: cancel the non-regulatory instrument, cancel the decision wholly or partly, adopt a new decision, or declare an action or failure to act unlawful and decide the issue on its merits. The disputed additional assessment or sanction should be stated separately from any unchallenged part of the decision.

When a complaint is left unreviewed

The higher tax authority does not reach the merits if it finds one of eight grounds (Article 234, Tax Code):

1. the applicant’s or representative’s signature is missing, or the representative’s authority is not proved;
2. the period has expired, no restoration request was made, or restoration was refused;
3. the applicant withdrew the complaint wholly or partly;
4. a complaint on the same grounds was filed earlier;
5. the decision has already been challenged under the procedure established by the Tax Code;
6. the filing procedure through the authority that made the inspection decision was breached;
7. the complaint does not satisfy the form and content requirements; or
8. the complaint concerns a pending criminal case or the taxpayer has gone to court on the same issue.

A decision to leave the complaint unreviewed is made within five days after receipt of the complaint or withdrawal request. Written notice is given within three days. The applicant may refile within the original remaining period after curing the defect, except where the complaint was withdrawn or another complaint on the same grounds had already been filed.

What changes after filing

Filing with the higher tax authority or a court suspends enforcement (Article 231, Tax Code) of the disputed decision or action. This includes collection of additionally assessed taxes and charges and application of financial sanctions. For an administrative complaint, suspension lasts until the higher authority decides; for a court complaint, it lasts until the judgment becomes final.

The taxpayer must notify the authority whose decision or conduct is challenged and attach proof of filing. In practice, this means a separate notice carrying the registration number, taxpayer-account receipt, or court acknowledgment. Without that proof, the authority may not have the information required to halt enforcement.

After administrative review, the original decision takes effect in the part not cancelled or challenged on the date of the higher authority’s decision. A new decision of the higher authority takes effect when adopted. If the complaint is left unreviewed, the lower decision takes effect on that decision date (Article 163, Tax Code), but not before the complaint period expires.

How the complaint is reviewed

The applicant may submit additional documents before a decision is made. The higher authority examines the complaint, the applicant’s evidence, and the lower authority’s file and, on its own initiative or at the applicant’s request, may arrange a hearing (Article 235, Tax Code).

The authority chooses one of five outcomes:

1. dismiss the complaint on the merits;
2. cancel the non-regulatory instrument;
3. cancel the decision wholly or partly;
4. cancel the decision in full and make a new decision; or
5. declare an official’s action or failure to act unlawful and decide the matter on its merits.

Additional documents relating to an assessment or liability decision are reviewed if the applicant explains why they could not be submitted to the lower authority in time. A material breach of the procedure for reviewing inspection materials also permits cancellation of the decision and a fresh review of the file, grounds, and documents.

An extension is permitted to obtain documents or information from lower authorities or when the applicant submits additional documents. The extension decision must also be sent to the applicant within three days.

A complaint may be withdrawn wholly or partly in writing before the decision. But withdrawal prevents refiling (Article 231, Tax Code) on the same grounds, so that procedural consequence must be considered before submitting a withdrawal.

What an appeal costs

An administrative complaint to the higher tax authority is free: the law charges no duty (Article 40) or fee for administrative complaints.

An exemption applies when filing in the administrative court. Business entities are exempt when challenging a state-body decision, action, or failure to act affecting their business activity; individuals are also exempt on filing (Article 10). This does not eliminate all litigation-cost risk. If a business applicant’s claims are refused wholly or partly, duty is collected after the case in proportion to the rejected claims; where a small business or individual succeeds, the duty is collected from the respondent unless the respondent is exempt.

The schedule to the law supplies the base rates used to determine possible duty.

The general allocation rule places costs on the unsuccessful party. The Plenum explains outcome-based recovery (paragraph 16, Plenum Decision No. 20), and postal and other proved litigation expenses may arise in addition to duty.

Example. A limited liability company challenges a business-related tax decision and pays no duty on filing. If the court refuses all relief and applies the legal-entity base rate, the calculation is 10 × one BRV = 4.400.000 UZS. For an individual, the base rate is 0.7 × one BRV = 308.000 UZS. The court determines the final allocation by reference to the outcome and available exemptions.

How to challenge the decision in court

The administrative court hears a request to invalidate a tax authority decision or declare its action or failure to act unlawful. The Supreme Court specifically explained that these tax disputes belong (paragraph 10, Plenum Decision No. 4) in the administrative courts. A claim to collect tax debt or a standalone monetary refund claim may belong in the economic or civil court; the relief sought must be distinguished.

The application is filed in the interdistrict administrative court where the authority is located (paragraph 13, Plenum Decision No. 24), or where the official works. If several respondents are in different places, the applicant may choose the court where any one respondent is located.

The court complaint must identify the authority or official, the decision’s details or the date and place of the action, the rights infringed, the rules allegedly breached, and the requested relief. Procedural documents and the disputed decision’s text (Article 187, CAS) are attached. If the applicant does not have a copy, that alone does not bar filing; the court may be asked to obtain it from the tax authority.

If the decision or conduct conflicts with the law and infringes the applicant’s rights, the court declares the decision invalid wholly or partly, or the action or failure to act unlawful. It may order the authority to adopt the legally required decision, take action, or otherwise cure the infringement and report on compliance (Article 189, CAS) to the court and applicant within one month after the judgment becomes final.

Which procedure applies to an administrative fine

A tax authority ruling in an administrative-offence case is not challenged under Chapter 30 of the Tax Code. It may be challenged before the higher authority or a district or city criminal court. The complaint is filed through the body that made the ruling or directly with the court, and the applicant is exempt from duty (Article 315, CAO).

This separate procedure must be distinguished from a financial sanction included in a tax-inspection decision. The period for an administrative-offence ruling is ten days after receipt of a copy. An audit or field-inspection decision carries the one-month administrative period and the suspension rules described above.

What the Tax Disputes Expert Council offers

A business entity that disagrees with a tax authority decision may apply to the Tax Disputes Expert Council under the Chamber of Commerce and Industry. The Council does not hear a dispute forming part of a criminal case or already pending in court. It adopts an opinion and sends it to the tax or other state authority for mandatory consideration (paragraph 5, PP-223 of 11 July 2025).

The resolution does not describe the Council’s opinion as a higher tax authority decision under Chapter 30 of the Tax Code. An application to the Council must therefore be distinguished from the formal administrative complaint: Tax Code and CAS periods remain tracked separately, and enforcement suspension is tied to filing with the higher tax authority or court.

What changed in 2026

• Plenum Decision No. 19 of 3 July 2026 clarified that a judge must check whether the tax authority halted enforcement of the challenged instrument after the court filing. If it did not, the court suspends enforcement on its own initiative.
• PP-138 of 15 April 2026 directed the creation, by 1 April 2027, of online court challenges by business entities against authorised bodies’ financial-fine rulings through the taxpayer account. The court must automatically notify interested authorities that enforcement is suspended for an accepted complaint. This is a future digital procedure; the existing filing methods apply until it launches.

How to preserve the right to challenge

The key document for tracking time is proof of when the applicant received the decision or learned of the action or failure to act. For a business, that is usually a record in the taxpayer account. Keep the decision together with the inspection report, objections, notice of the materials review, minutes, calculations, attachments, and dispatch receipts.

The complaint should separate facts, rules, and requested relief. For each disputed episode, state what the authority did or failed to do, which rule was breached, how the applicant’s right was affected, and what outcome is requested. Attach the disputed-amount calculation separately so that legal grounds and arithmetic remain distinct.

After filing, obtain registration evidence, notify the lower tax authority, and verify that collection has stopped. If the administrative route is chosen, continue tracking the six-month court period from the original decision. If the complaint is left unreviewed for a curable defect, cure it and refile before the original period expires.

Frequently asked questions

Can I file directly against the tax authority in court?

Yes. The Tax Code permits a challenge to a non-regulatory instrument, decision, action, or failure to act before the higher tax authority or in court. It does not state that a prior administrative complaint is mandatory for a tax decision. The dispute must still be classified correctly: a tax authority decision or conduct is challenged in the administrative court, while an administrative-offence ruling follows the separate CAO procedure.

Does a complaint suspend collection of assessed tax?

Yes. A complaint to the higher tax authority or court suspends enforcement of the disputed decision or action, including collection of additionally assessed taxes and charges and application of financial sanctions. The taxpayer must notify the authority whose decision is challenged and attach proof of filing. For a court complaint, suspension lasts until the judgment becomes final.

May I submit new documents after filing?

Yes. Additional documents may be submitted until the complaint is decided. If an assessment or liability decision is challenged and the documents were not provided to the lower authority in time, explain why. The higher authority reviews them when the applicant explains why timely submission was impossible. The applicant may also request a hearing for themselves or their representative.

What if the one-month period has expired?

File a restoration request with the complaint, describe the valid reason, and attach evidence. The higher tax authority decides whether to restore the period. Without a request, or if restoration is refused, the complaint is left unreviewed. Check the separate six-month court period as well: administrative review generally does not restart it.

Must I pay duty to challenge a tax authority?

No duty or fee is charged for an administrative complaint to the higher tax authority. Entrepreneurs in business-related disputes and individuals are exempt when filing a complaint in the administrative court. If the court refuses the requested relief wholly or partly, duty may be collected after the decision; the court also allocates other proved litigation expenses.