The Tax Procedure Code includes detailed provisions on the application of tax loss penalties and special irregularity penalties. Certain decisions are contested before the court. However, the court decisions are sometimes ignored by implementers and citizens still have to go the court for similar cases despite the precedent. On the other hand, there is lack of consensus between tax courts and the Council of State in respect of certain other cases. Therefore, different decisions may be rendered over the same matter. This impairs the confidence of citizens in the judiciary
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