It should be noted that according to Clause 52-8 of the TC (introduced by Law No. 540 to subsection 10 of section XX of the Transitional Provisions of the Tax Code) there is a suspension of the time limits established by Article 56 of the TC (in the part of the administrative appeal procedure) concerning complaints of taxpayers, received (to be received) by May 31, 2020 and / or not considered as of March 18, 2020. The exception is complaints about the lawfulness of declaring VAT refund claims and / or VAT deductibles.

Please note that such suspension does not give rise to any of the consequences provided for in Art. 56 of the Tax Code.

This means that if the complaint deadline is between April 2, 2020 and May 31, 2020 (inclusive), the deadline for filing such complaints is suspended and the taxpayer can file the appropriate complaint, taking into account the time elapsed before such suspension. As a result, such complaints must be accepted and considered by the supervisory authority in a general manner.

However, if the decision-making period by the regulatory authority on complaints lodged between 2 April 2020 and 31 May 2020 (inclusive) and / or not considered as of 18 March 2020 - falls within the period from 2 April 2020 to On 31 May 2020 (inclusive), the adoption of such decisions beyond the time limits specified in Article 56 of the TC, or the failure to send / pay taxpayers the decision of the head (his deputy or authorized person) of the supervisory authority to extend the time limits shall not lead to the satisfaction of taxpayers' complaints.

At the same time, given that the deadline is being extended, the supervisory authority is entitled to take the relevant decision from 1 June 2020, taking into account the time elapsed before such suspension.

PLEASE NOTE, the administrative deadlines for complaint handling do not stop and the consequences of the violation of their consideration provided for in Article 56.9, paragraph 56 of the Code on complaints about the legality of the declaration of value added tax and / or negative value from tax added value.