Abstract
The article presents the main scientific and practical results of the analysis of the situation regarding the exercise of state control over large taxpayers in terms of their compliance with tax legislation when applying for a value added tax refund.
 The article examines the peculiarities of exercising the rights of taxpayers to access a fair trial of claims for appealing tax assessment notices, the practice of considering the latter, and practical aspects of relations between taxpayers seeking VAT refunds and their counterparties. The author analyzes the practice of providing legal assistance to large taxpayers in the course of their legal activities. The author also analyzes the legal nature of the VAT refund procedure and identifies the key issues that arise when taxpayers apply for the relevant refund.
 The author proposes to amend the current legislation in order to eliminate the problematic issues arising when applying for a VAT refund, which create the basis for the corruption component, and also force the country to spend significant funds to ensure the work of a large number of tax service employees, as well as the forced costs of paying court fees when appealing against court decisions made in favor of taxpayers when appealing against tax notices (tax decision notices).
 The author proves that the problem of appealing tax assessment notices, which has its origin in taxpayers’ claims for VAT refunds, can be solved quite simply. As a result, it will be possible to improve the audit procedure, eliminate the costs of court fees in obviously losing cases, and eliminate significant gaps in the current legislation that complicate transparent business activities and create corruption risks.
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