دور المنازعات الجبائية في تقويم نتائج الرقابة الجبائية

Abstract

This study aims to shed light on the essential and pivotal role played by tax disputes as a legal and technical mechanism for evaluating and correcting the results arising from tax audits. This is to ensure a balance between the administration's authority to collect public treasury revenues and the taxpayer's right to protect their legal and financial position. This study focused on analyzing and discussing the dispute file of "Institution A" at the Sétif Provincial Tax Directorate, tracing the procedural path of the dispute starting from the accounting audit stage up to the Administrative Courts and the Council of State. The empirical results proved that judicial accounting expertise represents the cornerstone in resolving complex disputes, as it contributed to uncovering the material, mathematical, and discretionary errors that marred the audit reports. In the studied case, this led to a reduction of the claimed amounts by approximately 43% and an adjustment of the tax bases to align with the accounting reality. The study recommends the necessity of activating the role of administrative appeal committees and granting them broader technical powers to resolve disputes before they reach the courts. It also emphasizes the importance of digital transformation in modernizing the relationship between the administration and the taxpayer to ensure the stability of the legal positions for both parties.