EXTENDED TERRITORIAL COMPETENCE OF THE REVENUE BODIES INRELATION TO THEIR COMPETENCE TO ASSIGN AUDITS

Abstract

The paper reflects the author’s opinion with regard to interpretation case No. 2
of the Supreme Administrative Court under its registration record for 2024. The subject of the case
is to investigate the lawfulness of audit acts issued by revenue bodies from a territorial directorate
of the National Revenue Agency concerning persons in relation to whom, according to Article 8 of
the Tax-Insurance Procedure Code, such competence belongs to the revenue bodies of another
territorial directorate. Some panel of judges in the SAC deem such audit acts as null and void,  whereas in the opinion of other judges those acts are lawful and sound. In this respect, the present
paper examines the complex legal structure of the audits assignment by revenue bodies provided
with extended territorial competence.