THEORETICAL ISSUES ON LEGAL TAX RELATIONS
THEORETICAL ISSUES ON LEGAL TAX RELATIONS

Summary/Abstract: The legislator has offered up to now no legal definition of the legal tax relation and the legal provisions from the Tax Procedure Code in regard to the constitutive elements of the legal tax relation are neither coherent nor clear, managing to cause more confusions than clarifications. We hope that a rewriting of the Tax Procedure Code at which they are working these days would solve these issues, as the legal tax instability also starts from the wrong understanding of the concepts of relations of material tax law and the relation of tax procedural law. When drafting a procedure code, it is obvious that one should focus on the relations of procedural law, whereas in case of the Tax Procedure Code a mix up is produced in the general provisions of terms and notions specific to the relation of material tax law and the procedural tax law relation respectively and we believe this is not desirable.

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