Pre-trial settlement of tax disputes

The author analyzes the pre-trial settlement of tax disputes including the history of the issue, the evolution of the law governing them and the explanations given by the Higher Courts. Additionally, the article considers choosing the appropriate moment of full information disclosure regarding the auditing transaction within a tax audit. According to the author it is advisable to disclose such information not later than the filing appellate complaint. It is concluded that the current system of pre-trial settlement is an attempt to reach a compromise between the distrust of taxpayers to the tax authorities’ system, the need to make the correct decision after the tax audit and the desire of the state to reduce the workload on the system of the arbitration courts.