New Procedure for Appealing Tax Decisions: What Changes from September 1, 2026

Starting September 1, 2026, a new mechanism for extraterritorial appeal of tax authority decisions comes into effect. Now, a complaint against a tax inspectorate's decision may be reviewed not only by a higher tax authority but also by another authorized tax body designated by the Federal Tax Service. This change is established by Federal Law No. 425 of November 28, 2025.

The new procedure is designed to enhance the objectivity of tax dispute reviews and reduce the risk of subjective bias when appealing decisions. For businesses, this means additional opportunities to protect their rights during tax audits.

Previously, complaints against tax authority decisions were reviewed exclusively by a higher tax authority. The mechanism is now becoming more flexible: the Federal Tax Service will be able to authorize other tax bodies to review complaints as well.

The extraterritorial procedure means that a complaint may be reviewed by a tax authority not geographically connected to the one whose decision is being challenged. This reduces the likelihood of conflicts of interest and increases objectivity in dispute resolution.

The Federal Tax Service has already developed a draft order establishing the procedure for granting tax authority officials the powers to review complaints . According to the draft, such powers may be granted to officials meeting certain requirements:

• holding a position not lower than deputy head of the department responsible for complaint review;
• completing professional development courses and passing a professional exam (at least once every three years);
• possessing a higher education in "Law" or "Economics" and at least three years of work experience in a legal capacity or in tax authorities.

Officials' powers may be suspended (for example, during parental leave) or terminated (upon dismissal or if more than 10% of their decisions on complaints are overturned within a year).

The new procedure provides taxpayers with additional guarantees of objective complaint review. The ability to appeal to an authorized tax body that is not the higher authority of the body whose decision is being challenged reduces the risks of corporate solidarity and increases the chances of a fair decision.

For businesses, this means an additional tool for protecting their interests in disputes with tax authorities. However, it is important to understand that the new mechanism requires taxpayers to carefully prepare complaints and comply with all procedural requirements.

Although the new rules take effect on September 1, 2026, companies should prepare in advance:

1. Study the new appeal procedure and understand the opportunities it offers.
2. Review current tax disputes for potential use of the extraterritorial mechanism.
3. Incorporate the new rules into corporate procedures for interacting with tax authorities.
4. When tax disputes arise, carefully assess which body to choose for appeal — the higher authority or the authorized one.

Acsour experts are ready to help you understand the new procedure for appealing tax authority decisions:

• advise on the application of the new appeal mechanism;
• conduct a tax risk audit and develop a protection strategy.

Submit a request — our experts will help you assess risks and develop a protection strategy for tax disputes.