Opening by Complaint and Its Content
The requirements for the content of the complaint are not technical details: each element — organ, person, act, demand, circumstances — is the support of the subsequent examination, and their absence is recorded as a defect. The possibility of citing the Convention's norms and precedents widens the frame of argumentation: a tax question may be seen in an international-law perspective as well.
Administrative proceedings begin only upon submission of an administrative complaint; the complaint must be drafted in writing and meet the requirements of the Code. It must indicate: the name of the organ, the identity and address of the complainant, the challenged organ, the name of the challenged act, the demand, the circumstances grounding it and the list of attached documents; a copy of the act is attached where it was delivered. The complaint may state the act's inconsistency with the law on which the demand rests — and also the norms of the European Convention on Human Rights and the precedents of the European Court with which the act is claimed to be incompatible.