---
title: "Tax Assessment Appeals"
url: "https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-assessment-appeals-en"
field: "Dispute Resolution & Litigation"
description: "Tax assessment appeals: the one-month deadline, suspension of the challenged act and possible outcomes under the Administrative Code. Legal.ge."
reviewed: "2026-07-09"
updated: "2026-11-08"
publisher: "legal.ge"
---

# Tax Assessment Appeals

> Source: legal.ge, https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-assessment-appeals-en

## The Legal Framework for Challenging a Tax Assessment

A tax assessment — the act by which the tax authority determines the basis and amount of a taxpayer's liability — is an administrative-legal act, and it is challenged through the administrative complaint procedure established by the General Administrative Code of Georgia. The central norms of that mechanism are Articles 184, 180, 201 and 203 of the Code: the first governs the suspension of the challenged act's operation upon the filing of a complaint, the second fixes the appeal deadline, the third sets out the catalogue of decisions the examining organ must issue, and the fourth empowers the organ to amend the challenged act or declare it void. An administrative complaint must be submitted within one month of the day the act was published or officially communicated to the party, unless the law provides otherwise. Where the conduct of an administrative organ rather than an act is challenged, the month runs from the day the interested party learned of the action or the abstention from action. A missed deadline can be restored only if it elapsed due to force majeure or another valid cause — without restoration, the right of appeal is lost, which makes deadline control decisive for the entire challenge strategy.

## Suspension of the Challenged Assessment and Its Exceptions

Unless the law or a subordinate act adopted on its basis provides otherwise, the operation of the challenged act is suspended from the moment the administrative complaint is registered, and the administrative organ issues an individual administrative-legal act to that effect. From that moment, enforcement steps against the taxpayer grounded in the assessment halt. The suspension does not apply, however, where the act would increase the expenditures of the state or a municipality; where it is a police administrative-legal act adopted in connection with the protection of public order; where it was issued in a state of emergency or martial law on the basis of the corresponding law; or where postponing its execution would cause significant material damage or create a significant threat to public order or security. The decision to continue the operation of the act on one of these exceptional grounds is taken by the organ that issued the act or by its superior administrative organ, and that decision may be appealed to court under the procedure established by the legislation. At the same time, the interested party is entitled, under the statutorily prescribed procedure, to request the court to order the continuation of the suspended act's operation — a guarantee that matters when the suspension of an assessment itself paralyses the taxpayer's business processes.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-assessment-appeals-en

### What is the deadline for appealing an assessment?

One month from publication or official notification of the act, unless the law provides otherwise.

### Does a complaint suspend the act?

As a rule, yes — from registration of the complaint, subject to statutory exceptions.

### Can a missed deadline be restored?

Yes, on proof of force majeure or another valid cause.

### What outcomes are possible?

Satisfaction, partial satisfaction or refusal; postponement for additional materials; amendment of the act or a declaration that it is void.