pre-trial-appeal

What problem does it solve?

This Skill addresses the mandatory requirement under Article 138 of the Russian Tax Code to file a pre-trial appeal with tax authorities before pursuing arbitration court action for tax disputes, eliminating the risk of immediate case dismissal for skipping this required procedural step.

Core Features & Use Cases

• Appeal Eligibility Assessment: Guides users to identify the correct type of appeal (appellate vs. standard) based on the decision type and whether it has entered into force.
• Complaint Drafting: Provides a structured template for drafting legally compliant appeal complaints with required sections, legal arguments, and supporting evidence references.
• Deadline & Submission Management: Tracks strict filing deadlines, outlines official submission channels, and provides guidance for post-submission tracking and next steps.
• Use Case: A business that received an unfavorable tax audit decision from its local tax office (IFNS) can use this skill to draft a compliant appeal to the regional tax authority (UFNS) within the 1-month filing deadline.

Quick Start

Use the pre-trial-appeal skill to draft a compliant appeal complaint for the tax audit decision you received from your local tax office on [date of decision receipt].