Hearing as an institution aimed at clarifying evidentiary doubts in appeal tax proceedings

Abstract

The introduction into the General Tax Act of the institution of a hearing must be assessed positively. However, in tax proceedings, the hearing, essential for fulfilling the investigation of objective truth duty, may be used only to conduct evidence supplementary in character. Its application exceeding the limits set in Arts. 229 and 233 § 2 of the General Tax Act, would be contrary to the principle of two-instance tax proceedings, which significantly reduces its potential for effective practical application.